Keddy Mill HRS Documentation Record 

MEN000106078 

HRS DOCUMENTATION RECORD – REVIEW COVER SHEET 

Site Name: Keddy Mill 

 

EPA ID No.: MEN000106078 

 

Contact Persons 

Site Investigation: H&S/Nobis Environmental JV LLC. (HSNE) 

 Superfund Technical Assessment and Response Team III (START) 

 160 East Main Street, Suite 2F 

 Westborough, Massachusetts 01581 

 (508) 366-7442 

 (Mr. Denis McGrath, CHMM - (978) 703-6016) 

Documentation Record: HSNE 

 START 

 160 East Main Street, Suite 2F 

 Westborough, Massachusetts 01581 

 (508) 366-7442 

 (Mr. Denis McGrath, CHMM - (978) 703-6016) 

Site Contact: U.S. Environmental Protection Agency (EPA) Region 1 

 5 Post Office Square, Suite 100 

 Boston, Massachusetts 02109-3912 

 (617) 918-1407 

 (Ms. Martha Bosworth) 

Pathways, Components, or Threats Not Scored 

The ground water, drinking water threat of the surface water, soil exposure, and air migration pathways 

were not scored in this Hazard Ranking System (HRS) documentation record because the human food 

chain and environmental threats of the surface water migration pathway are sufficient to qualify the 

Keddy Mill for the National Priorities List (NPL). 

Ground Water Migration Pathway 

Based upon the location and proximity of the surrounding drinking water supply resources, no nearby 

drinking water supplies are known or suspected to have been impacted by a release from sources; 

therefore, this pathway has not been included in this HRS documentation record [Ref. 3]. 

Soil Exposure Pathway 

Soil sampling has been limited to the Keddy Mill property itself [Ref. 4, pp 23-34; Ref. 6, p. 19]. Based 

upon the lack of a resident population, terrestrial sensitive environments, and the relatively low nearby 

population targets, the resulting pathway score would not contribute significantly to the overall site score. 

This pathway has not been included in this HRS documentation record. 

Air Migration Pathway 

To date, a release of hazardous substances to air from on-site sources has not been documented; 

consequently, the resulting pathway score would not contribute significantly to the overall site score. This 

pathway has not been included in this HRS documentation record.
Keddy Mill HRS Documentation Record 

MEN000106078 1 

HRS DOCUMENTATION RECORD

Site Name: Keddy Mill Date Completed: December 2013

EPA Region: 1

Street Address of Site*: 7 Depot Street 

City, County, State, Zip Code: Windham, Cumberland County, Maine, 04062 

General Location in the State: Southwestern Maine

Topographic Map: Gorham, Maine, U.S. Geological Survey 7.5-Minute Quadrangle; 1957, 

Photorevised 1970, Photoinspected 1975 [Ref. 5] 

Latitude**: 43° 44' 05.83202 N 

Longitude**: 70° 25' 28.25026'' W 

Scores

Ground Water Pathway NS

Surface Water Pathway 100.00 

Soil Exposure Pathway NS

Air Pathway NS

HRS Site Score: 50.00 

NS = Not Scored 

*The street address, coordinates, and contaminant locations presented in this HRS documentation record 

identify the general area the site is located. They represent one or more locations EPA considers to be 

part of the site based on the screening information EPA used to evaluate the site for NPL listing. EPA 

lists national priorities among the known "releases or threatened releases" of hazardous substances; thus, 

the focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous 

substance has been "deposited, stored, disposed, or placed, or has otherwise come to be located." 

Generally, HRS scoring and the subsequent listing of a release merely represent the initial determination 

that a certain area may need to be addressed under CERCLA. Accordingly, EPA contemplates that the 

preliminary description of facility boundaries at the time of scoring will be refined as more information is 

developed as to where the contamination has come to be located.

** The geographic coordinates of the property were measured based on source sample SO-01-0002, 

located in the northwestern portion of the property, approximately 225 feet northwest of the former Melt 

Building [Ref. 7, pp. 1] (refer to Figure 3 of this HRS documentation record). 
Keddy Mill HRS Documentation Record 

MEN000106078 2 

WORKSHEET FOR COMPUTING HRS SITE SCORE 

S pathway S

2

pathway

1. Ground Water Migration Pathway Score (Sgw) Not Scored Not Scored

2. Surface Water Migration Pathway Score (Ssw)

(from Table 4-1, Line 30)

100.00 10,000

3. Soil Exposure Pathway Score (Ss) Not Scored Not Scored

4. Air Migration Score (Sa) Not Scored Not Scored

5. 5. Total of Sgw

2

+ Ssw

2

+ Ss

2

+ Sa

2

10,000

 

 

 

 

 

 

 

 

 

 

50.00
Keddy Mill HRS Documentation Record 

MEN000106078 3 

TABLE 4-1 - SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

Factor Categories & Factors Maximum 

Value

Assigned 

Value

Drinking Water Threat

Likelihood of Release:

1. Observed Release 550 550

2. Potential to Release by Overland Flow

2a. Containment 10 Not Scored

2b. Runoff 25 Not Scored

2c. Distance to Surface Water 25 Not Scored

2d. Potential to Release by Overland Flow (line 2a×[line 2b + line 2c]) 500 Not Scored

3. Potential to Release by Flood

3a. Containment (Flood) 10 Not Scored

3b. Flood Frequency 50 Not Scored

2c. Potential to Release by Flood (lines 3a×3b) 500 Not Scored

4. Potential To Release (lines 2d + line 3c; subject to a maximum of 500) 500 Not Scored

5. Likelihood of Release (higher of lines 1 and 4) 550 550

Waste Characteristics:

6. Toxicity/Persistence (a) Not Scored

7. Hazardous Waste Quantity (a) Not Scored

8. Waste Characteristics 100 Not Scored

Targets:

9. Nearest Intake 50 Not Scored

10. Population

10a. Level I Concentration (b) Not Scored

10b. Level II Concentration (b) Not Scored

10c. Potential Drinking Water Contamination (b) Not Scored

10d. Population (lines 10a+10b+10c) (b) Not Scored

11. Resources 5 Not Scored

12. Targets (lines 9+10d+11) (b) Not Scored

Drinking Water Threat Score:

13. Drinking Water Threat Score

([line 5 × line 8 × line 12] ÷ 82,500; subject to a maximum of 100) 100.00 Not Scored

Human Food Chain Threat

Likelihood of Release:

14. Likelihood of Release (copy from line 5) 550 550

Waste Characteristics:

15. Toxicity/Persistence/Bioaccumulation (a) 5.0×108

16. Hazardous Waste Quantity (a) 100

17. Waste Characteristics 1,000 320
Keddy Mill HRS Documentation Record 

MEN000106078 4 

TABLE 4-1 - SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

Factor Categories & Factors Maximum 

Value

Assigned 

Value

Targets:

18. Food Chain Individual 50 20

19. Population

19a. Level I Concentration (b) 0

19b. Level II Concentration (b) 0

19c. Potential Human Food Chain Contamination (b) 0.00003

19d. Population (lines 19a+19b+19c) (b) 0.00003

20. Targets (line 18 + line 19d) (b) 20.00003

Human Food Chain Threat Score:

21. Human Food Chain Threat Score

([line 14 × line 17 × line 20] ÷ 82,500; subject to a maximum of 100) 100.00 42.66

Environmental Threat

Likelihood of Release:

22. Likelihood of Release (copy from line 5) 550 550

Waste Characteristics:

23. Ecosystem Toxicity/Persistence/Bioaccumulation (a) 5.0×108

24. Hazardous Waste Quantity (a) 100

25. Waste Characteristics 1,000 320

Targets:

26. Sensitive Environments

26a. Level I Concentration (b) 0

26b. Level II Concentration (b) 30

26c. Potential Sensitive Environments Contamination (b) Not Scored

26d. Population (lines 26a+26b+26c) (b) 30

27. Targets (copy from line 26d) (b) 30

Environmental Threat Score:

28. Environmental Threat Score

([line 22 × line 25 × line 27] ÷ 82,500; subject to a maximum of 60) 60.00 60.00

Surface Water Overland Flow/Flood Migration Component Score for a 

Watershed

29. Watershed Score

(line 13 × line 21 × line 28; subject to a maximum of 100) 100.00 100.00

Surface Water Overland Flow/Flood Migration Component Score

30. Component Score (Sof), (highest of line 29 for all watersheds evaluated; 

subject to a maximum of 100. 100.00 100.00

(a) – Maximum value applies to waste characteristics category 

(b) – Maximum value not available 

(c) – Do not round to the nearest integer 
Keddy Mill HRS Documentation Record 

MEN000106078 5 

ACRONYMS AND ABBREVIATIONS

μg/kg Microgram per kilogram 

bgs Below ground surface 

CERCLA Comprehensive Environmental Response Compensation and Liability Act 

CFR Code of Federal Regulations 

cfs Cubic feet per second 

CLP Contract Laboratory Program 

CRQL Contract-Required Quantitation Limit 

CWA Clean Water Act 

EPA U.S. Environmental Protection Agency 

HRS Hazard Ranking System 

HSNE H&S\Nobis Environmental JV, LLC. 

HWQ Hazardous Waste Quantity 

LLC Limited Liability Corporation 

MDIFW Maine Department of Inland Fisheries and Wildlife 

MEDEP Maine Department of Environmental Protection 

mg/kg Milligram per kilogram 

NPL National Priorities List 

NWI National Wetlands Inventory 

PCB Polychlorinated biphenyl 

PPE Probable point of entry 

SCDM Superfund Chemical Data Matrix 

SI Site Inspection 

SICP Self-Implementing Cleanup Plan 

SQL Sample Quantitation Limit 

SOW Statement of Work 

START Superfund Technical Assessment and Response Team 

TDL Target Distance Limit 

TOC Total Organic Carbon 

TSCA Toxic Substances Control Act 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 
1 MILE RADIUS

MOST-UPSTREAM

PROBABLE POINT OF ENTRY

KEDDY MILL

MOST-DOWNSTREAM

PROBABLE POINT OF ENTRY

Copyright:© 2011 National Geographic Society, i-cubed

DRAWN BY: DM

PROPERTY LOCATION

KEDDY MILL

7 DEPOT STREET

WINDHAM, MAINE

0 1,000 2,000 4,000

Feet 1:24,000

Path: O:\Active\87000 EPA Region I START\87001.10_Keddy_Mill_HRS_Windham_ME\Technical Data\GIS\Maps_and_Figures\Final_Doc_Record\Fig_1_Keddy_Mill_Windham_ME_Site_Locus.mxd

Topography Data Source: National Geographic through ESRI

USGS Quadrangle Name: Gorham, Maine, Revised 1975.

SIte Boundary: Reference 11

Location of all features is approximate. Map is for reference

purposes only. H&S/Nobis Environmental JV, LLC makes no claims,

warranties, representations, expressed or implied, relating

to the completeness, accuracy, or reliability of the data shown.

160 East Main Street Suite 2F

Westborough, MA 01581

FIGURE 1

TDD No. SA-01-13-01-0001

QUADRANGLE LOCATION

DATE: August, 2013

Keddy Mill HRS Documentation Record

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Legend

Approximate Fenceline

Probable Points of Entry

Intermittent Stream

Overland Segment

Approximate Property Boundary

Source Areas

DRAWN BY: DM

PROPERTY LAYOUT

KEDDY MILL

7 DEPOT STREET

WINDHAM, MAINE

1:1,800

Basemap Image Source: Bing through ESRI portal

Building Locations Source: Reference 14, p. 140

Property Boundary and Abutters Source: Reference 11

Remaining Data: Refs. 35, 43, 60

Location of all features is approximate. Map is for reference purposes only.

H&S/Nobis Environmental JV, LLC makes no claims, warranties, representations,

expressed or implied, relating to the completeness, accuracy, or reliability of the data.

160 East Main Street Suite 2F

Westborough, MA 01581

FIGURE 2

TDD No. SA-01-13-01-0001

DATE: August, 2013

0 75 150 300

Feet

Keddy Mill HRS Documentation Record

MEN000106078 7
Path: O:\Active\87000 EPA Region I START\87001.10_Keddy_Mill_HRS_Windham_ME\Technical Data\GIS\Maps_and_Figures\Final_Doc_Record\Fig_3_Keddy_Mill_Source_1.mxd

Legend

Source Sample Location

Approximate Fenceline

Approximate Property Boundary

Source No. 1

DRAWN BY: DM

SOURCE No. 1 SAMPLE LOCATIONS

KEDDY MILL

7 DEPOT STREET

WINDHAM, MAINE

1:1,800

160 East Main Street Suite 2F

Westborough, MA 01581

FIGURE 3

TDD No. SA-01-13-01-0001

DATE: August, 2013

0 75 150 300

Feet

Basemap Image Source: Bing through ESRI portal

Property Boundary and Abutters Source: Reference 11

Source Location: Ref. 35

Location of all features is approximate. Map is for reference purposes only.

H&S/Nobis Environmental JV, LLC makes no claims, warranties, representations,

expressed or implied, relating to the completeness, accuracy, or reliability of the data.

Keddy Mill HRS Documentation Record

MEN000106078 8
Path: O:\Active\87000 EPA Region I START\87001.10_Keddy_Mill_HRS_Windham_ME\Technical Data\GIS\Maps_and_Figures\Final_Doc_Record\Fig_4_Keddy_Mill_Source_2.mxd

Legend

Background Sample Location

Source Sample Location

Approximate Fenceline

Approximate Property Boundary

Source No. 2

DRAWN BY: DM

SOURCE No. 2 SAMPLE LOCATIONS

KEDDY MILL

7 DEPOT STREET

WINDHAM, MAINE

1:1,800

160 East Main Street Suite 2F

Westborough, MA 01581

FIGURE 4

TDD No. SA-01-13-01-0001

DATE: August, 2013

0 75 150 300

Feet

Basemap Image Source: Bing through ESRI portal

Property Boundary and Abutters Source: Reference 11

Source Location: Ref. 43

Location of all features is approximate. Map is for reference purposes only.

H&S/Nobis Environmental JV, LLC makes no claims, warranties, representations,

expressed or implied, relating to the completeness, accuracy, or reliability of the data.

Keddy Mill HRS Documentation Record

MEN000106078 9
Terminus of the

15-Mile TDL

Saccarappa

Cumberland

Mallison Falls

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Legend

Probable Points of Entry

Dam

Class B Portion of the 

Target Distance Limit

Class C Portion of the

Target Distance Limit

Delineated Wetland Frontage

Town Boundary

DRAWN BY: DM

TARGET DISTANCE LIMIT

KEDDY MILL

7 DEPOT STREET

WINDHAM, MAINE

1:60,059

Basemap Image Source: Bing through ESRI portal

PPE Locations: Ref. 35, 43; Dam Location: Ref. 5; Wetland Frontage: Ref. 57; 

TDL Classification Data: Ref. 54, p. 11

Municipal Boundaries Source: Maine GIS (MEGIS)

Location of all features is approximate. Map is for reference purposes only.

H&S/Nobis Environmental JV, LLC makes no claims, warranties, representations,

expressed or implied, relating to the completeness, accuracy, or reliability of the data.

160 East Main Street Suite 2F

Westborough, MA 01581

FIGURE 5

TDD No. SA-01-13-01-0001

DATE: August, 2013

0 0.5 1 2

Miles

Mallison Falls

Copyright:© 2011 National

Geographic Society, i-cubed

Keddy Mill HRS Documentation Record

MEN000106078 10
0 225 450 900

Feet 1:5,400

Path: O:\Active\87000 EPA Region I START\87001.10_Keddy_Mill_HRS_Windham_ME\Technical Data\GIS\Maps_and_Figures\Revised_Final_Doc_Record\Fig_6_Sed_Samples_Keddy_Mill_Windham_ME.mxd

Legend

Background Sediment Sampling Location

Sediment Sampling Location

Delineated Wetland Frontage

Approximate Property Boundary

Inset Located

Approximately

1.5 Miles Upstream of Site

DRAWN BY: DM

SEDIMENT SAMPLE LOCATIONS

KEDDY MILL

7 DEPOT STREET

WINDHAM, MAINE

160 East Main Street Suite 2F

Westborough, MA 01581

FIGURE 6

TDD No. SA-01-13-01-0001

DATE: September, 2013

0 350 700

Feet

Inset Scale

Basemap Image Source: Bing through ESRI portal

Property Boundary Source: Ref. 11

Sediment Locations: Ref. 29

Wetland Frontage Source: Ref. 57

Location of all features is approximate. Map is for reference purposes only.

H&S/Nobis Environmental JV, LLC makes no claims, warranties, representations,

expressed or implied, relating to the completeness, accuracy, or reliability of the data.

Keddy Mill HRS Documentation Record

MEN000106078 11
Keddy Mill HRS Documentation Record 

MEN000106078 12

REFERENCES

 

Reference

Number Description of Reference

[1] U.S. Environmental Protection Agency (EPA). 1990. Hazard Ranking System; Final Rule, 

40 CFR 300, Appendix A The Complete Hazard Ranking System; Final Rule. Available 

from: 

http://www.epa.gov/superfund/sites/npl/hrsres/index.htm#HRS Rule. December 14. 132

pages

[2] U.S. Environmental Protection Agency (EPA). 2004. Superfund Chemical Data Matrix 

Methodology. Available from 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm. January. Excerpt, TOC & 

Introduction, Appendices BI , BII, and March 31, 2012 update. 130 pages.

[3] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note, Keddy Mill, RE: 

Drinking water supply. TDD No. SA-01-13-01-0001. March 12. 34 pages.

[4] H&S/Nobis Environmental JV LLC. 2013. Final Site Inspection Report for Keddy Mill; 

Windham, Maine. January. 140 Pages.

[5] 7.5 by 15 Minute US Geological Survey Map – Gorham ME Quadrangle. 1957. 

Photorevised in 1970. Photoinspected in 1975. 1 page.

[6] Summit Environmental Consultants. 2011. Memorandum with attachments Re: 

Supplemental Sampling, April 2011; Keddy Mill, Windham, Maine. July 25. 72 Pages.

[7] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note, Keddy Mill, RE: 

Geographic Coordinates. TDD No. SA-01-13-01-0001. August 6. 2 pages.

[8] Search Superfund Site Information; Superfund; US EPA. 2013. 

http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0106078. Keddy Mill. Accessed 

February 12. 1 page.

[9] Town of Windham, Cumberland County, Maine 2011 Property Maps Map 38. September 

28, 2011. 1 page.

[10] Cumberland County Registry of Deeds. 2011. Quitclaim Deed Without Covenant; 

Document Number 54058; Book 29050 Page 322 - 326. 5 pages.

[11] Northeast Civil Solutions. 2012. Building No. 118; Central Falls Station; General 

Boundary Survey with Sample Locations; Drawing No. CD-67192. February 10. 1 page.

[12] Summit Environmental Consultants. 2011. Phase I Environmental Site Assessment; Keddy 

Mill, 7 Depot Street, Windham, Maine. March 17. 224 Pages.

[13] Dole, Samuel. 1906. Windham in the Past. Published by the Merrill & Webber Company, 

Auburn Maine. 624 pages.

[14] S.W. Cole Engineering, Inc. 1997. Environmental Site Assessment Phase I & II; Former 

Steel Mill Property; Route 202 and Depot Street, Windham, Maine. November 17. 140 

pages.

[15] Consla Geotechnical Engineering, Inc. 1993. Phase I Limited Environmental Assessment, 

Lot No. 7 of Map 38, Windham Township, South Windham, Cumberland County, Maine. 

March 18. 14 pages.

[16] A.P. Green, Harbison-Walker, and NARCO. 2003. Material Safety Data Sheet-Kast-O-Lite 

26 LI. April 4. 12 pages.
Keddy Mill HRS Documentation Record 

MEN000106078 13

Reference

Number Description of Reference

[17] Jacques Whitford. 2003. Phase II Supplemental Investigation. August. 9 pages (cover page 

not available)

[18] Summit Environmental Consultants, Inc. 2010. Memorandum to Jean Firth and Laura Gay 

at Maine Department of Environmental Protection; re: Keddy Mill, Windham, Maine. 

May 20. 1 page.

[19] Summit Environmental Consultants, Inc. 2011. Memorandum to Tom Bartell (Town of 

Windham), Laura Gay and Jean Firth (Maine Department of Environmental Protection), 

Frank Gardner (U.S. EPA), and Steve Etzel (Hudson Realty Group) with attachments RE: 

Keddy Mill, Windham, Maine. January 5. 43 pages.

[20] Summit Environmental Consultants, Inc. 2011. Memorandum to Tom Bartell (Town of 

Windham), Jean Firth, Laura Gay, Troy Smith (Maine Department of Environmental 

Protection), and Renee Lewis (Village at Little Falls, LLC) with attachments RE: Electrical 

Conductivity Testing, Keddy Mill, Windham, Maine. October 24. 46 pages.

[21] Summit Environmental Consultants, Inc. 2011. Memorandum to Tom Bartell (Town of 

Windham), Jean Firth, Laura Gay (Maine Department of Environmental Protection), Frank 

Gardner (U.S. EPA), and D. Todd Coffin (GEI) with attachments RE: Supplemental 

Sampling, April 2011, Keddy Mill, Windham, Maine. July 25. 72 pages.

[22] H&S/Nobis Environmental JV, LLC. 2012. Final Potential Hazardous Waste Site 

Preliminary Assessment Form; Keddy Mill, 7 Depot Street, Windham, Maine. March 21. 5 

pages.

[23] Reference Number Reserved.

[24] Maine Department of Environmental Protection. 2005. Oil & Hazardous Materials Report 

Spill No. P-868-2005. Printed 11/2/2006. 4 pages.

[25] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note, Keddy Mill with 

attachments RE: Source Nos. 1 and 2 Geographic Coordinates. TDD No. SA-01-13-01-

0001. February 26. 6 pages.

[26] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note, Keddy Mill RE: 

Keddy Mill Site Inspection Field Logbook Notes. TDD No. SA-01-12-03-0001. February

28. 22 pages.

[27] H&S/Nobis Environmental JV, LLC. 2012. Trip Report for Keddy Mill, 7 Depot Street, 

Windham, Maine. October. 23 pages.

[28] H&S/Nobis Environmental JV, LLC. 2012. Field Task Work Plan for Soil and Sediment 

Sampling; Keddy Mill, Windham, Maine. July 10. 46 pages.

[29] Nobis Engineering, 2012. Surficial Soil, Sediment, and Sludge Sampling. Data Collection 

Sheets. September. 49 pages.

[30] U.S. EPA. 2012. USEPA CLP Organics COC (Lab Copy) Chain of Custody Records; Case 

No. 42787.; COC Nos. 1-091112-170508-0002; 1-091312-091322-0004; 1-091412-

084526-0006. September. 14 pages.

[31] U.S. EPA. 2006. Modifications Updating SOM01.1 to SOM01.2. October 5. 319 pages.

[32] U.S. EPA. 1996. Region I, EPA-New England Data Validation Functional Guidelines for 

Evaluating Environmental Analyses. July, (December rev.). 509 pages.
Keddy Mill HRS Documentation Record 

MEN000106078 14

Reference

Number Description of Reference

[33] DeRuzzo, G. (Nobis Engineering, Inc.). 2013. Tier II Organic Data Validation 

Memorandum: Stage 2B Validation Electronic and Manual (S2BVEM). RE: Case No. 

42787; SDG No. A4742. February 21. 125 pages.

[34] DeRuzzo, G. (Nobis Engineering, Inc.). 2013. Tier II Organic Data Validation 

Memorandum: Stage 2B Validation Electronic and Manual (S2BVEM). RE: Case No. 

42787; SDG No. A4744. February 21. 137 pages.

[35] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note, Keddy Mill, RE: 

Source No. 1 Area Calculation. TDD No. SA-01-13-01-0001. February 26. 2 pages.

[36] ENSR Corporation, 2007. Historic Flooding in Major Drainage Basins, Maine. October. 

277 pages.

[37] Presumpscot River Plan Steering Committee, Presumpscot River Fisheries Subcommittee, 

and Land & Water Associates. 2002. Fisheries Conditions, Issues and Options for the 

Presumpscot River. May 28. 79 pages.

[38] DeRuzzo, G. (Nobis Engineering, Inc.). 2013. Tier II Organic Data Validation 

Memorandum: Stage 2B Validation Electronic and Manual (S2BVEM). RE: Case No. 

42787; SDG No. A4743. February 21. 108 pages.

[39] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2012. Project Note, Keddy Mill with 

attachments RE: Presumpscot River flow rates and Surface Water Categories. TDD No. 

SA-01-11-12-0001. February 27. 4 pages.

[40] Nobis Engineering, 2012. Chain of Custody Record; Keddy Mill. September 18. 1 page.

[41] DeRuzzo, G. (Nobis Engineering, Inc.). 2012. Tier I Modified Data Validation 

Memorandum RE: Case No. D001; SDG No. 360-42832. October 1. 30 pages.

[42] Ransom Environmental Consultants, Inc. 2006. Plan for Self-Implementing Cleanup of 

PCB Remediation Waste – Phase I; 7 Depot Street, South Windham, Maine. April 28. 52 

pages.

[43] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note, Keddy Mill, RE: 

Source No. 2 Area Calculation. TDD No. SA-01-13-01-0001. February 26. 2 pages.

[44] DeRuzzo, G. (Nobis Engineering, Inc.). 2013. Adjusted Values for Aroclor Data: RE: Case 

No. 42787; SDG Nos. A4742, A4743, A4744. February 22. 410 pages.

[45] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note, Keddy Mill, RE: 

Sediment Sample Distances. TDD No. SA-01-13-01-0001. February 16. 3 pages.

[46] U.S. Department of Health and Human Services; Public Health Service – Agency for Toxic 

Substances and Disease Registry. 2000. Toxicological Profile for Polychlorinated 

Biphenyls (PCBs). November. 948 pages.

[47] U.S. Department of Health and Human Services; Public Health Service – Agency for Toxic 

Substances and Disease Registry. 001. D ivision of Toxicology ToxFAQsTM -

Polychlorinated Biphenyls. February. 2 pages.

[48] Town of Windham, Maine. 1991 (revised 2012). Zoning Map. October 1. 1 page.

[49] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note with attachments 

RE: Maine Department of Inland Fisheries and Wildlife Presumpscot River Coldwater Fish 

Stocking Program. August 22. 4 pages.
Keddy Mill HRS Documentation Record 

MEN000106078 15

Reference

Number Description of Reference

[50] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note RE: Phone 

Conversation Record – Brad Goulet (SAPPI/Warren Release Papers Hydro Manager). 

February 22. 1 page.

[51] Maine Department of Inland Fisheries and Wildlife. 2012. 2011 Year to Date Stocking 

Report. January 3. 42 pages. The report is generated by county.

[52] Bosworth, M. (EPA Region 1). 2012. Memorandum to file. Subject: Documenting Fishery 

on the Presumscot [sic] River South of Keddy Mill. July 25. 1 page.

[53] GEI Consultants, Inc. 2010. Self-Implementing Remediation Report; Keddy Mill PCB 

Cleanup, Windham, Maine. August 10. 54 pages.

[54] Maine Revised Statutes (MRS) Title 38 Section 467; Classification of Major River Basins. 

18 pages. Current through September 1, 2012.

http://www.mainelegislature.org/legis/statutes/38/title38sec467.html

[55] Maine Revised Statutes (MRS) Title 38 Section 465; Standards for Classification of Fresh 

Surface Waters. 5 pages. Current through September 1, 2012. 

http://www.mainelegislature.org/legis/statutes/38/title38sec465.html

[56] 33 U.S. Code (USC) 1251 et seq.; Federal Water Pollution Control Act. November 27, 

2002. 234 pages.

[57] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2012. Memorandum to M. Bosworth 

(EPA) with attachments; Wetland Delineation Memorandum. August 1. 20 pages.

[58] U.S. Environmental Protection Agency (EPA). 2004. Polychlorinated Biphenyl Inspection 

Manual; EPA-305-X-04-002. August. Excerpt. 20 pages.

[59] U.S. Geological Survey. 2013. 2011 Minerals Yearbook; Slag – Iron and Steel [Advanced 

Release]. January. 10 pages.

[60] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note, Keddy Mill, RE: 

Overland Flow Component Description. TDD No. SA-01-13-01-0001. March 29. 5 pages.

[61] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Memorandum with 

attachments; Subject: Supplemental Wetland Delineation Memorandum; Keddy Mill, 

Windham, Maine; CERCLIS ID No. MEN000106078; RDD No. SA-01-13-01-0001. 

April 2. 5 pages.

[62] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note, Keddy Mill, RE: 

CERCLIS/RCRIS/TSCA/NPDES/VRAP- Facilities. TDD No. SA-01-13-01-0001. August

26. 117 pages.

[63] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note with attachments, 

Keddy Mill, RE: CLP Form Is. TDD No. SA-01-13-01-0001. March 29. 50 pages.

[64] DeRuzzo, G. (H&S/Nobis Environmental JV, LLC). 2013. Project Note, Keddy Mill, RE: 

Sample Adjusted CRQLs. TDD No. SA-01-13-01-0001. August 26. 2 pages.

[65] U.S. Environmental Protection Agency (EPA). 1995. EPA Office of Compliance Sector 

Notebook Project; Profile of the Fabricated Metals Products Industry; EPA-310-R-95-007.

September. 156 pages.

[66] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note with attachments, 

RE: Keddy Mill Source Nos. 1 and 2 Descriptions. TDD No. SA-01-13-01-0001. August 9. 

10 pages.
Keddy Mill HRS Documentation Record 

MEN000106078 16

Reference

Number Description of Reference

[67] McGrath, D. (H&S/Nobis Environmental JV, LLC). 2013. Project Note with attachments, 

RE: Keddy Mill - Sources of PCBs Along the Presumpscot River Between Gambo Dam 

and Mallison Dam. TDD No. SA-01-13-01-0001. August 12. 3 pages.

[68] State of Maine Department of Environmental Protection. 2010 Integrated Water Quality 

Monitoring and Assessment Report. 328 Pages.

[69] U.S. Environmental Protection Agency (EPA). 2013. 2010 Waterbody Report for 

Presumpscot River. Available from 

http://ofmpub.epa.gov/tmdl_waters10/attains_waterbody.control?p_list_id=&p_au_id=ME

0106000103_608R01&p_cycle=2010&p_state=ME. August 12. 2 Pages.
Keddy Mill HRS Documentation Record 

MEN000106078 17

SITE SUMMARY – Keddy Mill 

The Keddy Mill property is located at 7 Depot Street, Windham, Cumberland County, Maine 

[Ref. 8]. The geographic coordinates as measured from Source No. 1 sampling location SO-01-

0002, located in the northwestern portion of the property, approximately 225 feet northwest of 

the former Melt Building are 43°44'05.83202” north latitude and 70° 5 ' 8.25026" west longitude 

(refer to Figures 1, 2, and 3 of this HRS documentation record) [Ref. 7]. The 6.93-acre Keddy 

Mill property is identified on the Town of Windham, Maine tax assessor’s Map 38 as Lot 7 [Ref. 

9, Ref. 22, p. 2]. The property is currently owned by Keddy Mill Enterprises, LLC, as recorded 

at the Cumberland County registry of Deeds in Book 29050 Pages 322-326 [Ref. 10, pp. 1-5].

The property is located in the Little Falls portion of Windham, Maine [Ref. 5; Ref. 12, p. 5]. The 

property is bounded to the north by Depot Street; to the northeast by a partially-developed 

commercial parcel also owned by Keddy Mill Enterprises, LLC; to the east by a former Maine 

Central Railroad right-of-way (currently owned by Maine Department of Transportation); to the 

south and southwest by undeveloped property owned by S.D. Warren Company and the 

Presumpscot River; to the west by the Presumpscot River, a parking lot property owned by S.D. 

Warren Company, and a hydroelectric dam and power generating station (also owned by S.D. 

Warren Company); and to the northwest by an occupied apartment complex owned by the South 

Windham Housing Corporation (Figure 2) [Ref. 11; Ref. 12, pp. 2, 11].

The Keddy Mill property is currently vacant, but is improved with a derelict two-story concrete 

industrial structure with a full basement constructed in the early 1900s. The property formerly 

contained several additional industrial buildings which have since been demolished [Ref. 12, p. 

10; Ref. 15, pp. 2, 11]. 

A visit to the Keddy Mill property was conducted by EPA and its contractor on April 26, 2012 

during the performance of the EPA Site Inspection (SI). In addition to the vacant concrete 

building, EPA and contractor personnel observed that the property was enclosed by a chain-link 

fence and locked fence gates [26, p. 1]. 

Several additional property features were noted during the visit including: 

 Concrete aboveground storage tank (AST) cradles along the eastern property boundary 

(purpose unknown) [Ref. 26, p. 1] 

 Derelict rail spur and overhead rail crane located adjacent to the southeastern portion of 

the facility buildings [Ref. 14, p. 19; Ref. 26, p. 1] 

 Slag materials located on the ground surface along the derelict rail spur and along the 

western bank of the Presumpscot River [Ref. 26, p. 2] 

 Several large hammering units within the basement of the former Melt Building [Ref. 26, 

p. 3]. It could not be determined if these units were hydraulic. 

 The exposed south face of a deposited mixture of demolition debris with an undetermined 

number of crushed metal drums located north of the buildings. This deposit appeared to 

be a pile of debris with the southern face sloping steeply upwards and flattened out on the 

top. Areas of stressed vegetation were noted on the top of the pile in which materials 

including slag, metal pieces, fabric, and brick were noted on the ground surface. [Ref. 26, 

p. 4] 
Keddy Mill HRS Documentation Record

MEN000106078 18

 A concrete pad formerly containing a transformer substation (no transformers were 

present) southwest of the buildings. Ceramic insulators and wiring were noted in this 

area as well [Ref. 14, p. 20; Ref. 26, p. 2]. 

The Keddy Mill site for HRS scoring purposes consists of two sources and associated releases. 

Source No. 1 is an area of contaminated soil located to the north of the former Boiler House and 

Forge Shop [Ref. 25, p. 2; Ref. 26, p. 4]. Source No. 2 is an area of contaminated soil near the 

former Melt Building [Ref. 25, p. 4] (see Figure 2 of this HRS documentation record). 

Polychlorinated biphenyls (PCBs) Aroclor-1242, Aroclor-1248 and/or Aroclor-1254 have been 

documented in Source Nos. 1 and 2 (see Section 2.2, Source Nos. 1 and 2 of this HRS 

documentation record). These hazardous substances have also been documented in sediment 

samples collected from the Presumpscot River, which receives runoff from Source Nos. 1 and 2, 

indicating that a release has occurred to the surface water migration pathway (see Section 4.0 of 

this HRS documentation record). 

Facility Operations

Many industrial activities were conducted on the Keddy Mill property between 1756 and 1997. 

Specifically, a sawmill, grist and wool carding mills, wood pulp and box-board manufacturing, 

steel manufacturing and fabrication of heavy equipment buckets, manufacturing of fire 

suppression piping and materials, and a small machine shop and equipment storage previously 

operated on the property [Ref. 12, p. 19, Ref. 13, pp. 231, 232, Ref. 14, pp. 13, 17, Ref. 15, pp. 2, 

10]. Table 1 summarizes historic ownership and operational activities conducted on the Keddy 

Mill property beginning in 1756. 

Table 1 - Historic Ownership and Generalized Operations

Approximate Years of 

Ownership

Owner Operations and Events of Significance References

Prior to 1756-unknown William Knight Sawmill Ref. 13, p. 231; 

Ref. 14, pp. 15, 16

Unknown - 1847 Unknown Grist mill and wool carding mills Ref. 13, p. 232; 

Ref. 14, p. 17

1847-1853+/- Unknown Sawmill (disassembled and relocated in 

approximately 1853) Ref. 14, p. 17

1853-1875 Unknown Unoccupied Ref. 13, p. 232

1875-1900 Charles A. Brown 

Company 

Wood pulp and box-board manufacture; 

constructed large mill complex on the property

Ref. 13, pp. 232, 

233

1900- March 1940 Androscoggin Pulp 

Company

Wood pulp and box-board manufacture; 

Enlarged the mill complex on the property with 

the construction of several new buildings

Ref. 13, p. 233

March 1940-July 1945 Cumberland 

Securities Group

Operations at this time are not known, but are 

assumed to be wood pulp and box-board 

manufacture

Ref. 12, p. 19; 151

July 1945-December 1945 Windham Fibers

Operations at this time are not known, but are 

assumed to be wood pulp and box-board 

manufacture

Ref. 12, p. 19

December 1945-August 1953 Maine Steel Steel manufacture and fabrication of heavy 

equipment buckets

Ref. 12, p. 19; Ref. 

15, p. 10

August 1953-December 1953 Weiland, Hoodin, 

Buthckes, Jelin Unknown Ref. 12, p. 19

December 1953-August 1954 Irving Fox Unknown Ref. 12, p. 19

August 1954-June 1961 Atlantic Mills, Inc. Unknown Ref. 12, p. 19

June 1961-November 1969 Keddy 

Manufacturing Co. Unknown Ref. 12, p. 19

November 1969-August 1973 Grinnell Corporation Fire suppression piping and materials 

manufacture Ref. 15, pp. 2, 10
Keddy Mill HRS Documentation Record 

MEN000106078 19

Table 1 - Historic Ownership and Generalized Operations

Approximate Years of 

Ownership

Owner Operations and Events of Significance References

August 1973-May 1974 Park Corporation Liquidation of heavy machinery within the 

former mill complex Ref. 15, pp. 2, 10

May 1974-July 1975 Lawrence J. Keddy Operations not known. Ref. 12, p. 19; Ref. 

15, p. 2

January 1975-January 1978 National Metal 

Converters

Operated by National Metal Converters (also 

known as New England Steel Company); 

operations not known; presumed steel 

manufacture

Ref. 15, p. 2

January 1978-April 1993 Lawrence J. Keddy

Unknown; however a Phase I Investigation 

performed in 1993 stated that reinforcing steel 

had been manufactured on the Keddy Mill 

property

Ref. 14, p. 15; Ref. 

15, p. 3

January 1993-November 1997 Barnard-Marquit 

Corp.

Unknown; in November 1997, the facility was 

used as a small machine shop and equipment 

storage

Ref. 12, p. 19

November 1997-September 

2002

Presumpscot/ 

Phoenix Corp. Unknown Ref. 12, p. 19

September 2002-November 

2006 Lumas, Inc. Unknown Ref. 12, p. 19

November 2006-October 2011 HRC-Village at Little 

Falls, LLC Presumed property redevelopment Ref. 12, p. 19

October 2011-date of report Keddy Mill 

Enterprises, LLC Presumed property redevelopment Ref. 10, pp. 1-5

Previous Phase I environmental investigations provided some information regarding the usage of 

each of the Keddy Mill property buildings in place at the time. Table 2 provides a summary of 

the information accumulated and observations made during previous investigations regarding 

each of the buildings on the property, either currently or formerly. 

Table 2 - Historic Building/Structure Usage

Building

Identification

Building Usage & 

Notable Observations

References

Manufacturing and 

Office Building 

Formerly used as a reinforcing steel manufacturing building 

and a machine shop. Also housed administrative offices. Bags 

of “Kast-O-Lite” were present, which was a lining material for 

use in melt furnaces. Furnaces were observed in the basement 

of this building. A portion of the Presumpscot River flows 

beneath the western portion of the building. Floor drains 

draining to the Presumpscot River were observed in the 

basement.

Ref. 14, pp. 20, 21; Ref. 15, p. 3; Ref. 

16; Ref. 26, p. 3.

Forge and Remelt 

Shop

Formerly contained two bunker oil-fired rotary remelt furnaces 

and reinforcing steel manufacturing equipment. Building is 

now demolished.

Ref. 15, pp. 3, 4; Ref. 14, p. 19

Boiler House Contained six aboveground storage tanks that contained

bunker oil (presumably to fire boilers/furnaces). The building 

also contained a coal hopper and brick smoke stack. Building 

is now demolished.

Ref. 14, p. 21; Ref. 15, pp. 2, 3, 4

Melt Building Formerly used for steel manufacturing machinery storage. 

Several mechanical hammers were noted in the basement. It 

could not be determined if these were powered hydraulically.

Oily stains were observed on the walls near these units. The 

stains were described as bond breaker and consisted of a 

mixture of oil and graphite, which was piped to the hammer 

units.

Ref. 12, p. 19; Ref. 15, pp. 3, 4; Ref. 26, 

p. 3

Storage and 

Manufacturing 

Building

Formerly used for steel manufacturing machinery storage. A 

steam generator was observed on the first floor, and fuel oil 

pump was located at the northwestern corner of the building. A 

large petroleum stain was observed surrounding the fuel pump.

Ref. 15, pp. 3, 4
Keddy Mill HRS Documentation Record 

MEN000106078 20

Table 2 - Historic Building/Structure Usage

Building

Identification

Building Usage & 

Notable Observations

References

Press Building Formerly used for heavy equipment storage. Ref. 15, pp. 3, 4

Overhead Crane & 

Rail Spur

Rail cars containing scrap steel were unloaded using an 

overhead crane. Steel was transported to other portions of the 

mill and were melted into steel billets.

Ref. 14, p. 19

Specific operational and waste management practices used at the Keddy Mill property are not 

currently known. Steel manufacture was initiated in December 1945 with the fabrication of 

heavy equipment buckets [Ref. 15, p. 10]. Subsequent steel manufacturing operations included 

fire suppression piping and materials manufacture, and reinforcing steel manufacture [Ref. 15, 

pp. 2, 3, 10, 12]. As reported in a 1993 Phase I investigation of the Keddy Mill property, the mill 

formerly accepted scrap steel which was melted into steel billets [Ref. 14, p. 19]. 

The presence of PCBs at the Keddy Mill property was not suggested in available documentation 

until the 1993 Phase I recommended that the concrete transformer substation pad area be 

investigated for the presence of PCBs [Ref. 15, p. 13]. A subsequent Phase I investigation 

performed on the Keddy Mill property identified three transformers on this pad and one polemounted transformer located south of the buildings [Ref. 14, pp. 22, 23]. Testing of the contents 

of these transformers was not performed. 

In July 2005, a release of between 30 and 40 gallons of PCB-containing fluid from vandalized 

electrical equipment within the former Keddy Mill property buildings was reported to the Maine 

Department of Environmental Protection (MEDEP) [Ref. 24, p. 2]. Subsequent correspondence 

between the responding contractor, EPA, and MEDEP stated that the release date could not be 

determined, and that the release was to be treated as an old/historic release [Ref. 24, p. 4]. As a 

response to the presence of PCBs within the buildings, a Toxic Substances Control Act (TSCA) 

Self-Implementing Cleanup Plan (SICP) was prepared in April 2006 and approved by EPA in 

June 2006 [Ref. 42, p. 1; Ref. 53, p. 2]. Numerous samples of interior building media were 

collected including: surface wipes of building interior surfaces, sludge, interior soil, wood, and 

debris. The results indicated that the PCB contamination was widespread throughout the interior 

of the Keddy Mill property buildings [Ref. 42, pp. 9, 10, 15-17, 20, 21]. Details pertaining to this 

plan and the subsequent cleanup action are discussed below in the Environmental Removal 

Actions section. 

No transformers were noted during the April 2012 EPA Site Inspection (SI) site visit. No details 

regarding the disposition of the PCB electrical components are currently known. 

The presence of PCB-containing electrical components on the property as recently as 2005, long 

after industrial activities vacated the property, suggests that PCB-containing electrical 

components were utilized on the property when it was in operation. 

In addition to electrical components, EPA has generally identified hydraulic systems, particularly 

in the steel manufacturing industry, as containing PCBs. The EPA states that these hydraulic 

systems operate at high pressure and often leak [Ref. 58, p. 15]. Several hammer units were 

observed in the basement of the former Melt Building [Ref. 26, p. 3]. It could not be determined 

if these units were hydraulic. 
Keddy Mill HRS Documentation Record 

MEN000106078 21

Cutting oil also formerly contained PCBs [Ref. 46, p. 494]. No cutting tools or similar 

machinery were observed during the April 2012 EPA SI site visit; however, as a former heavy 

equipment bucket and piping fabrication shop, it is likely that such equipment was utilized on the 

Keddy Mill property to cut down large steel pieces into smaller pieces [Ref. 65, pp 23, 24]. 

Soil sampling efforts performed in 2010 suggested to the investigators that the PCB 

contamination detected on the property was the result from two sources of PCBs (cutting oils and 

electrical components) [Ref. 19, pp. 1, 2]. This assertion was based on the levels, spatial 

distribution, and matrix of materials where PCB contamination was detected during the 

investigation [Ref. 19, p. 2]. 

Facility Environmental Investigations

Several environmental investigations have been undertaken on the Keddy Mill property. Table 3 

provides a summary of the previous environmental investigations performed. 

Table 3 - Previous Environmental Investigations

Performing 

Company/Agency

Performed 

For

Investigation 

Type

Report 

Date

Tasks 

Performed

Sample 

Types 

Collected

Hazardous 

substances 

Detected

References

Consla 

Geotechnical 

Engineering, Inc.

Mr. 

Laurence 

Keddy

Phase I Limited 

Environmental 

Assessment

3/18/93 Property

history, 

interviews, 

visit

None NA Ref. 15, pp.

1, 2, 10

S.W. Cole 

Engineering, Inc.

Mr. George 

Wood

Phase I & II 

Environmental 

Site 

Assessment

11/17/99 Property

history, 

interviews, 

visit; soil 

sampling, 

test pitting, 

limited 

petroleumrelated soil 

excavation

Soil

(subsurface)

Arsenic, 

cadmium, 

chromium, 

copper, lead, 

nickel, zinc, 

petroleum

hydrocarbon

Ref. 14, pp. 

1, 3, 7, 21-

24

Jacques Whitford 

Company, Inc

Unknown Supplemental 

Site 

Investigation

3/9/04 Visit, soil 

sample 

collection

Soil

(subsurface)

Petroleum 

hydrocarbons, 

PCBs (in 

excess of 

TSCA), 

metals

Ref. 17, pp. 

1, 3-9

Ransom 

Environmental 

Consultants, Inc.

Village at 

Little Falls, 

LLC

Plan for SelfImplementation 

Cleanup of 

PCB 

Remediation 

Waste-Phase I

4/28/06 Visit, PCB 

sample 

collection

Surface 

wipes of 

building 

interior 

surfaces, 

sludge, 

interior soil, 

wood, 

debris

PCBs Ref. 42 pp. 

1, 8-10, 15-

17, 21

Summit 

Environmental 

Consultants, Inc.

Town of 

Windham 

(through 

MEDEP)

Soil Sampling 

Memorandum 

5/20/10 Visit, sample 

collection

Soil from 

piles in 

buildings

PCBs Ref. 18
Keddy Mill HRS Documentation Record 

MEN000106078 22

Table 3 - Previous Environmental Investigations

Performing 

Company/Agency

Performed 

For

Investigation 

Type

Report 

Date

Tasks 

Performed

Sample 

Types 

Collected

Hazardous 

substances 

Detected

References

Summit 

Environmental 

Consultants, Inc.

Town of 

Windham 

(through 

MEDEP)

Soil Sampling 

Memorandum

1/5/11 Visit, sample 

collection

Surface soil 

from 

exterior 

areas

PCBs Ref. 19, pp. 

1-3, 5-9

Summit 

Environmental 

Consultants, Inc.

Town of 

Windham 

(through 

MEDEP)

Phase I 

Environmental 

Site 

Assessment

3/17/11 Property 

history 

analysis, 

visit, records 

review, 

interviews

None NA Ref. 12, pp. 

1, 2

Summit 

Environmental 

Consultants, Inc.

Town of 

Windham 

(through 

MEDEP)

Supplemental 

Sampling 

Memorandum

7/25/11 Soil and 

concrete 

core samples

Surface soil 

from 

exterior 

areas and 

concrete 

core 

samples

PCBs Ref. 6, pp. 

1-6, 8, 10-

12, 19

Summit 

Environmental 

Consultants, Inc.

Town of 

Windham 

(through 

MEDEP)

Electrical 

Conductivity 

Testing

10/24/11 Visit, soil 

drilling, and 

conductivity 

probing

None NA Ref. 20, pp. 

1, 2

H&S/Nobis 

Environmental JV, 

LLC

EPA Preliminary 

Assessment

3/21/12 Visit None NA Ref. 22, pp. 

1-5

H&S/Nobis 

Environmental JV, 

LLC

EPA Site Inspection 1/15/13 Visit, 

property 

history 

review, 

sample 

collection

Surface soil, 

Slag 

deposits,

Sediment

PCBs Ref. 4, pp. 

1, 7, 8, 26-

33, 36-42, 

56, 57

Notes:

MEDEP - Maine Department of Environmental Protection

NA - Not applicable

PCBs - Polychlorinated Biphenyls

TSCA - Toxic Substances Control Act

EPA - U.S. Environmental Protection Agency

Environmental Removal Actions

Two removal actions were performed on the Keddy Mill property by the property owners at the 

time [Ref. 14, pp. 3, 26-28; Ref. 53, p. 2]. 

The first removal action took place in 1997, and involved the excavation of 10.88 tons of 

petroleum-impacted soil from the north-central portion of the property. Post-excavation samples 

were not collected for PCB analysis [Ref. 14, pp. 26-28]. As this removal action was conducted 

outside of both sources, this action does not impact either of the sources evaluated in this HRS. 

In May and July 2010, the second removal action was performed in accordance with the TSCA 

SICP submitted in 2006 [Ref. 42, p. 1; Ref. 53, p. 2]. The SICP included three phases of cleanup 

actions within the Keddy Mill property buildings: 
Keddy Mill HRS Documentation Record 

MEN000106078 23

 Phase I – Remove PCB-contaminated fuel oils remaining in piping and PCBcontaminated sludge, dirt, debris, and oily materials within the buildings [Ref. 42, pp. 4, 

5]. 

 Phase II – Perform additional testing for PCB contamination on building interior porous 

surfaces. A separate plan was to be prepared to describe this activity, but has not yet 

been prepared [Ref. 42, p. 5]. 

 Phase III – Perform additional testing of soil surrounding and underlying the buildings. 

A separate plan was to be prepared to describe this activity, but has not yet been prepared 

[Ref. 42, p. 5]. 

The May through July 2010 removal action encompassed only Phase I of the SICP [Ref. 53, p. 

3]. The remaining phases of the plan have not yet been completed. The implemented cleanup 

action involved: the removal and disposal of sludge, dirt, and oily debris from the building 

floors; the removal and disposal of heavy oil coating from building floors, walls, and stationary 

equipment; cleaning and capping of fuel supply piping; and placement of polyethylene and 

approximately 2 inches of clean sand fill over exposed soils that may contain PCBs in broken 

areas of concrete. No excavation was performed [Ref. 53, pp. 1, 3]. The solid waste generated 

by the 2010 removal was transported under a hazardous waste manifest as a PCB solid mixture 

(93,256 kilograms) to CWM Chemical Services, LLC in Model City, New York. The liquid 

waste was transported under a hazardous waste manifest as a PCB liquid (235 kilograms) to 

Cycle Chem, Inc. of Elizabeth, New Jersey [Ref. 53, pp. 17-37].

No post-cleanup samples were collected in association with Phase I of the SICP. In April 2011, 

concrete core sampling was performed by MEDEP as part of a subsequent investigation. Sample 

results indicated that PCBs were present in concrete floor materials located throughout each of 

the buildings and on all levels at concentrations ranging between not detected to 130 mg/kg, with 

depths ranging to at least 1 inch into the concrete. Additionally, PCBs were detected in the 

concrete of one wall on the first floor at 9.4 mg/kg [Ref. 21, pp. 4, 5].

Neither the 1997 petroleum contamination removal nor the 2010 Phase I SICP removal affect 

sources and associated releases scored in this HRS documentation record (refer to Section 2.2.2, 

Source Nos. 1 and 2, and Section 4.1.2.1.1, Observed Release of this HRS documentation 

record).
Source Characterization 

Source No. 1 

Keddy Mill HRS Documentation Record 

MEN000106078 24

2.2 SOURCE CHARACTERIZATION 

 

2.2.1 SOURCE IDENTIFICATION

 

Name of Source: Contaminated Soil Associated with Deposited Slag Materials

Source Number: Source No. 1 

Source Type: Contaminated Soil 

Description and Location of Source:

Source No. 1 is located in the north-central portion of the Keddy Mill property (refer to Figure 2 

of this HRS Documentation Record). The geographic coordinates of the approximate center of 

the area of contaminated soil associated with Deposited Slag Materials are 43° 44' 06.23'' North 

Latitude by 70° 25' 26.51'' West Longitude [Ref. 25, pp. 1-3] (refer to Figure 3 of this HRS 

documentation record). 

A May 1970 aerial photograph was taken by the U.S. Geological Survey (USGS) during steel 

manufacturing and fabrication operations on the Keddy Mill property. The photograph shows an 

area in the north-central portion of the property as receiving both light and dark colored materials 

[Ref. 66, pp. 1-3]. 

The 1997 Phase I/II investigation identified that an area in the north-central portion of the Keddy 

Mill property contains fill materials consisting of wood, metal, slag, brick, and crushed drums. 

The investigation report stated that the south face of the fill area slopes steeply upward and is flat 

at the top [Ref. 14, pp. 18, 23]. 

In 2011, soil samples were collected for PCB field screening and laboratory analysis. The results 

indicated that PCBs were consistently detected throughout the Source No. 1 area [Ref. 21, pp. 

10-16, 19]. 

Soil borings advanced within Source No. 1 during the 2011 supplemental investigation contained 

a dark brown sand with little silt and gravel with some wood, brick, metal filings, concrete, metal 

shavings and slag. The soil borings indicate that similar materials exist to depths of 14.5 to 19 

feet below grade [Ref. 20, pp. 42, 43]. Portions of the top of Source No. 1 were devoid of 

vegetation, while surrounding areas were vegetated by grasses and small brush [Ref. 26, p. 4]. 

No evidence of cover material was recorded on the boring logs, or noted by EPA or HSNE 

START during visits to the Keddy Mill property. The contents of the soil borings are consistent 

with what was documented in the samples collected during the 2012 EPA SI [Ref. 29, pp. 1-5, 

32, 33]. 

During the 2012 EPA SI, eight soil samples were collected from Source No. 1 from between 0 

and 1.3 feet below ground surface [Ref. 29, pp. 1-5, 32, 33] (refer to Figure 3 of this HRS 

Documentation Record). The samples contained PCBs at concentrations ranging from 47 J 

μg/kg to 3,000 μg/kg (Aroclor-1248 and Aroclor-1254) [Ref. 33, pp. 26, 27]. 
Source Characterization 

Source No. 1 

Keddy Mill HRS Documentation Record 

MEN000106078 25

Information regarding the process(es) used during the operations on the Keddy Mill property to 

generate the slag material found in Source No. 1, the mechanism used to deposit the slag, or the 

approximate amount of slag deposited is not available. It is known that steel manufacturing slag 

is generated by the addition of slagging agents or fluxes to blast furnaces and steel furnaces to 

remove impurities from iron ore, steel scrap, and other ferrous feedstock. The formed slag floats 

on the molten crude iron or steel and is tapped from the furnace and cooled [Ref. 59, p. 2]. 

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH SOURCE 

- Source Samples

Surface soil samples listed in Table 4 were collected from Source No. 1 in September 2012 

during the EPA SI [Ref. 26, pp. 8, 12, 13; Ref. 29, pp. 1-5, 32, 33]. The samples were collected 

in accordance with the EPA approved Field Task Work Plan dated July 10, 2012 [Ref. 27, pp. 2, 

16; Ref. 28]. Eight source samples were collected between 0 and 1.3 feet below grade from 

various locations within Source No. 1 [Ref. 26, pp. 8, 12, 13]. 

Table 4 - Source No. 1 Sample Description

Sample ID

Sample 

Depth

(feet bgs)

Sample Date Sample Description References

SO-01-0002 0 to 0.5 9/11/12 Dark brown medium to coarse sand with little 

silt and medium to fine gravel. Dry.

Ref. 26, pp. 12, 13; 

Ref. 29, p. 1

SO-02-0002 0 to 0.9 9/11/12

Dark brown fine, medium, and coarse sand with 

trace silt, and fine gravel. Metal slag material 

observed along with a white fabric-like material. 

Dry.

Ref. 26, pp. 12; 

Ref. 29, p. 2

SO-03-0002 0 to 0.9 9/11/12

Brown fine sand with trace silt, medium and 

coarse sand, and trace fine gravel. Metal slag 

material observed along with a white fabric-like 

material. Dry.

Ref. 26, pp. 12; 

Ref. 29, p. 3

SO-DUP01-0002 0 to 0.9 9/11/12 Field duplicate sample of SO-03-0002. Ref. 26, pp. 12; 

Ref. 29, p. 3

SO-04-0002 0 to 0.3 9/11/12

Brown fine sand with little medium sand and 

trace coarse sand, silt, and fine gravel. Metal 

slag and shavings material observed along with a 

white fabric-like material. Dry.

Ref. 26, pp. 12; 

Ref. 29, p. 4

SO-05-0002 0 to 1.3 9/11/12

Dark brown fine to medium sand with little silt 

and trace coarse sand and fine to coarse gravel. 

Slag, brick, metal shavings and white fabric 

materials were observed. Moist.

Ref. 26, pp. 12; 

Ref. 29, p. 5
Source Characterization 

Source No. 1 

Keddy Mill HRS Documentation Record 

MEN000106078 26

Table 4 - Source No. 1 Sample Description

Sample 

Sample ID Depth Sample Date Sample Description References

(feet bgs)

SS-06-0002 0 to 1 9/10/12

Brown fine sand and silt, trace coarse sand, trace 

fine and coarse gravel. Wood, brick, and fabric 

(wool?) noted in sample.

Ref. 26, p. 

29, p. 32

8; Ref. 

SS-07-0002 0 to 0.3 9/10/12

Brown fine sand, little silt, trace medium to 

coarse sand, and fine gravel. Brick pieces noted 

in sample. Moist.

Ref. 26, p. 

29, p. 33

8; Ref. 

Notes: 

bgs - Below ground surface 

The Source No. 1 samples were submitted to a Contract Laboratory Program (CLP)-participating 

laboratory for analysis of PCBs in accordance with CLP Organic Statement of Work (SOW) 

SOM01.2 [Ref. 26, pp. 8, 12, 13; Ref. 27, pp. 16; Ref. 29, pp. 1-5, 32, 33; Ref. 30, pp. 2, 5, 6; 

Ref. 31; Ref. 33, pp. 1, 26, 27; Ref. 35, p. 1, 35].

Chemists not involved with the sample collection performed a Tier II level validation of the 

analytical results in accordance with the Region 1 – EPA New England Data Validation 

Functional Guidelines for Evaluating Environmental Analyses [Ref. 32; Ref. 33, p. 1; Ref. 34, p. 

1; Ref. 38, p. 1]. The Chain of Custody forms are included as Reference No. 30. The CLPprovided analytical data sheets are provided in References 33, 34, and 38. Field notes and field 

data collection summaries are presented in Reference 26 and Reference 29, respectively. 

For the purposes of Source No. 1 evaluation, the analytical results of these eight source soil 

samples confirm the presence of PCB mixtures Aroclor-1248 and Aroclor-1254 [Ref. 33, pp. 26, 

27; Ref. 34, p. 35] (see Table 5 below) at levels significantly above background levels (see Table 

8 and Table 9 under the Source No. 2 evaluation). Source No. 1 has been documented to contain 

hazardous substances in accordance with the HRS [Ref. 1, p. 51587]. 

Table 5 - Hazardous Substances Associated with Source No. 1

Sample ID Hazardous 

Substance Bias Hazardous Substance Concentration

Sample-Adjusted 

CRQL References

SO-01-0002 Aroclor-1254 None 1,900 J ug/kg 350 ug/kg Ref. 33, p. 26; 

Ref. 44, pp. 1, 

2, 4; Ref. 63, 

pp. 2, 3

SO-02-0002 Aroclor-1248 None 990 J ug/kg 360 ug/kg Ref. 34, p. 35; 

Ref. 44, pp. 1, 

2, 5; Ref. 63, 

pp. 4, 5

SO-02-0002 Aroclor-1254 None 1,900 J ug/kg 360 ug/kg Ref. 34, p. 35; 

Ref. 44, pp. 1, 

2, 5; Ref. 63, 

pp. 4, 5

SO-03-0002 Aroclor-1248 None 2,300 ug/kg 350 ug/kg Ref. 33, p. 26; 

Ref. 44, pp. 1, 

2 ,4; Ref. 63, 

pp. 6, 7
Source Characterization 

Source No. 1 

Keddy Mill HRS Documentation Record 

MEN000106078 27

Table 5 - Hazardous Substances Associated with Source No. 1

Sample ID Hazardous 

Substance Bias Hazardous Substance Concentration

Sample-Adjusted 

CRQL References

SO-03-0002 Aroclor-1254 None 3,000 ug/kg 350 ug/kg Ref. 33, p. 26; 

Ref. 44, pp. 1, 

2, 4; Ref. 63, 

pp. 6, 7

SO-DUP01-0002 Aroclor-1248 None 2,000 ug/kg 350 ug/kg Ref. 34, p. 34; 

Ref. 44, pp. 1, 

2, 5; Ref. 63, 

pp. 12, 13

SO-DUP01-0002 Aroclor-1254 None 2,900 J ug/kg 350 ug/kg Ref. 34, p. 34; 

Ref. 44, pp. 1, 

2, 5; Ref. 63, 

pp. 12, 13

SO-04-0002 Aroclor-1254 None 1,200 J ug/kg 350 ug/kg Ref. 33, p. 26; 

Ref. 44, pp. 1, 

2, 4; Ref. 63, 

pp. 8, 9

SO-05-0002 Aroclor-1248 None 660 J ug/kg 360 ug/kg Ref. 34, p. 35; 

Ref. 44, pp. 1, 

2, 5; Ref. 63, 

pp. 10, 11

SO-05-0002 Aroclor-1254 None 1,800 ug/kg 360 ug/kg Ref. 34, p. 35; 

Ref. 44, pp. 1, 

2, 5; Ref. 63, 

pp. 10, 11

SS-06-0002 Aroclor-1254 None 180 J ug/kg 39 ug/kg Ref. 33, p. 27; 

Ref. 44, pp. 1, 

2, 4; Ref. 63, 

pp. 14

SS-07-0002 Aroclor-1254 None 47 J ug/kg 40 ug/kg Ref. 33, p. 27; 

Ref. 44, pp. 1, 

2, 4; Ref. 63, 

pp. 14

Notes: 

CRQL = Contract Required Quantitation Limit 

J = Reported value is an estimate based upon an evaluation of quality control parameters. An analysis of 

potential bias associated with samples was performed and is presented as part of Reference 44. Although 

some of the presented data is J-qualified, it does not exhibit a bias. 

ug/kg = micrograms per kilogram 

Sample-adjusted CRQLs are equivalent to HRS CRQLs as the adjusted (due to moisture, matrix, dilution, etc.) 

limits are based on the CLP CRQLs. In this instance, the sample-adjusted CRQLs are equivalent to sample 

quantitation limits [Ref. 64]. 

List of Hazardous Substances Associated with Source

Aroclor-1248 

Aroclor-1254 
Source Characterization 

Source No. 1 

Keddy Mill HRS Documentation Record 

MEN000106078 28

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY 

Observations, sample collection logs, and soil boring logs from previous investigations do not 

indicate the presence of a maintained engineered barrier cover or runoff control management 

system [Ref. 20, pp. 42, 43; Ref. 29, pp. 1-5, 32, 33]. Therefore, a containment value of 10 as 

noted in Table 6 below is assigned for the surface water pathway [Ref. 1, Table 4-2, pp. 51609, 

51610]. 

Table 6 - Hazardous Substances Available to Pathways

Containment Description Containment 

Factor Value

References

Gaseous Release to Air: Not Evaluated Not Scored

Particulate Release to Air: Not Evaluated Not Scored

Release to Ground Water: Not Evaluated Not Scored

Release to Surface Water via Overland Flow and/or Flood: No 

maintained engineered barrier or runoff management system is 

present to control this source

10 Ref. 1, p. Table 4-2, pp. 

51609, 51610; Ref. 29, pp. 

1-5, 32, 33

2.4.2 HAZARDOUS WASTE QUANTITY 

The hazardous waste quantity for Source No. 1 was assigned based on the area factor value for 

 ource Type “Contaminated Soil” [Ref. 1, Table -5, p. 51591]. Due to the lack of available 

information (i.e., hazardous waste manifests, waste analytical results or characteristics, discharge 

records, etc.), neither the Hazardous Constituent Quantity nor the Hazardous Wastestream 

Quantity were evaluated. 

2.4.2.1.1 Hazardous Constituent Quantity 

Description

Information on the quantity (in pounds) of individual hazardous substances in Source No. 1 is 

not available to evaluate Tier A, hazardous constituent quantity. The number of samples 

collected is not statistically representative of the range of concentrations throughout the source. 

Therefore, it is not possible to adequately determine a hazardous constituent quantity for Source 

No. 1 with reasonable confidence [Ref. 1, Section 2.4.2.1.1, p. 51591]. Scoring proceeds to the 

evaluation of Tier B, hazardous wastestream quantity [Ref. 1, Section 2.4.2.1.2, p. 51591]. 

Hazardous Constituent Quantity value assigned = Not Scored

2.4.2.1.2 Hazardous Wastestream Quantity 

Description

The information on the total mass of all hazardous wastestreams and CERCLA pollutants and 

contaminants for Source No. 1 is not sufficient to evaluate Tier B, hazardous wastestream 

quantity. There is insufficient information that documents wastestream disposal; therefore, it is 

not possible to adequately determine a reasonably complete hazardous wastestream quantity for 
Source Characterization 

Source No. 1 

Keddy Mill HRS Documentation Record 

MEN000106078 29

Source No. 1 [Ref. 1, Section 2.4.2.1.2, p. 51591]. Scoring proceeds to the evaluation of Tier C, 

volume [Ref. 1, Section 2.4.2.1.3, p. 51591]. 

Hazardous Wastestream Quantity value assigned = Not Scored

2.4.2.1.3 Volume 

Description

The depth of Source No. 1 is not known and the extent of the source has not been determined. 

The information available is not sufficient to evaluate Tier C, volume, as required by the HRS 

[Ref. 1, Section 2.4.2.1.3, p. 51591]. Scoring proceeds to the evaluation of Tier D, area [Ref. 1, 

Section 2.4.2.1.4, p. 51591]. 

Volume value assigned = 0 

2.4.2.1.4 Area 

Description

Based upon the analytical results of the source samples, observations of the materials within 

Source No. 1, and the presence of previous investigation data indicating that PCB contamination 

is present throughout the Source No. 1 area, the areal extent of this source is defined using the 

perimeter made up of the six source samples (refer to Figure 3 of this HRS Documentation 

Record). As presented on Table 7 below, Source No. 1 occupies an area of approximately 

15,247 square feet [Ref. 21, pp, 10-16, 19; Ref. 35, p. 1, 2].

Table 7 – Area

Source Type Units (Square feet) References

Contaminated Soil 15,247 Ref. 35, pp. 1, 2

To assign a Hazardous Waste Quantity value to a ource Type “Contaminated Soil”, the area in 

square feet is divided by 34,000 [Ref. 1, Table 2-5, p. 51591]. 

Sum in square feet: 15,247 

Equation for Assigning Value [Ref. 1, Table 2-5, p. 51591]: 15,247 ÷ 34,000 = 0.448 

Area value assigned = 0.448

2.4.2.1.5 Source Hazardous Waste Quantity Value

The Hazardous Waste Quantity Hazardous Waste Quantity (HWQ) for Source No. 1 is assigned 

based on the Area Factor Value (0.448) [Ref. 1, Table 2-5, p. 51591]. 

Source No. 1 Hazardous Waste Quantity Value = 0.448
Source Characterization 

Source No. 2 

Keddy Mill HRS Documentation Record 

MEN000106078 30

2.2 SOURCE CHARACTERIZATION 

 

2.2.1 SOURCE IDENTIFICATION

 

Name of Source: Contaminated Soil in the Vicinity of the Former Melt Building

Source Number: Source No. 2 

Source Type: Contaminated Soil 

Description and Location of Source:

Source No. 2 is located in the vicinity of the former Melt Building (refer to Figure 4 of this HRS 

Documentation Record). Source No. 2 is in the shape of a backwards “C”, and consists of large 

areas located north and south of the former Melt Building. The geographic coordinates of the 

approximate center of the northern portion of Source No. 2 are 43° 44' 06.23'' North Latitude by 

70° 25' 26.51'' West Longitude, and the coordinates of the approximate center of the southern 

portion of Source No. 2 are 43° 44' 06.23'' North Latitude by 70° 25' 26.51'' West Longitude 

[Ref. 25, pp. 1-6].

Transformers were present on the Keddy Mill property in a substation located southwest of the 

buildings as well as within the Keddy Mill property buildings [Ref. 14, pp. 22, 23, 140; Ref. 24, 

p. 2]. EPA has identified that the oil within hydraulic systems associated with the steel 

manufacturing industry may contain PCBs [Ref. 58, p. 15]. Additionally, metal cutting oil also 

formerly contained PCBs [Ref. 46, p. 494]. Both of these materials may have been utilized on 

the Keddy Mill property [Ref. 65, pp. 23, 24]. 

Soil samples collected in May 2010, January 2011, and July 2011 identified that much of the 

surface soil surrounding the Keddy Mill property buildings has been impacted by the presence of 

PCB mixtures including Aroclor-1248, Aroclor-1254, and Aroclor-1260 [Ref. 21, pp. 10-12]. 

The total PCB concentrations detected during these investigations ranged from a low 

concentration of 0.2 milligrams per kilogram (mg/kg), to a high of 1,100 mg/kg [Ref. 21, p 11; 

Ref. 19, p. 6]. Many of these soil samples were collected from within the top 6 inches of soil 

[Ref. 21, pp. 10-12; Ref. 19. pp. 5-9]. The PCBs in soil appeared to be related to the presence of 

metal filings associated with cutting oils, slag materials, and transformers on the Keddy Mill 

property [Ref. 21, p. 5]. 

In September 2012, EPA collected soil samples (0 to 2 feet below grade) from Source No. 2. 

[Ref. 26, pp. 7-13, 20; Ref. 29, pp. 27-49]. The samples contained PCBs (Aroclor-1242, 

Aroclor-1248, and Aroclor-1254) at concentrations above background concentrations [Ref. 33, 

pp. 27, 28; Ref. 34, pp. 35, 36; Ref. 44, pp. 4, 5]. 
Source Characterization 

Source No. 2 

Keddy Mill HRS Documentation Record 

MEN000106078 31

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE 

- Background Samples

On September 9, 2012, two background surface soil samples (SS-01-0002 and SS-02-0002) were 

collected as part of the EPA SI [Ref. 26, pp. 7-13, 20; Ref. 29, pp. 27, 28] (refer to Figure 4 of 

this HRS Documentation Record). Background samples were collected from 0 to 2 feet below 

grade and are compared to source samples collected at similar depths [Ref. 26, p. 6, 7; Ref. 29, 

pp. 27, 28]. These sample locations were chosen to represent background conditions because (1) 

the soil type at these locations was the same soil type as samples collected from Source No. 2; 

and (2) based upon previous sample results, the background sampling locations appeared to have 

been minimally effected by past facility operations [Ref. 19, p. 13; Ref. 21, p. 19]. These 

background surface soil samples were collected in accordance with the EPA-approved Field 

Task Work Plan dated July 10, 2012 [Ref. 28]. 

The background and the source soil samples from Source No. 2 were collected during the same 

sampling event, in accordance with the same sampling methods, from similar depths and 

matrices, and were analyzed using the same laboratory using the same analytical method: CLP 

SOW SOM01.2 [Ref. 26, pp. 7-13, 20; Ref. 29, pp. 27-49; Ref. 30, pp. 1-3, 6-9, 12, 13; Ref. 33, 

p. 1; Ref. 34, p. 1; Ref. 38, p. 1]. 

Table 8 below provides a summary of the background soil sample descriptions. 

Table 8 - Background Soil Sample Descriptions

Sample ID Sample Depth

(feet bgs)

Sample 

Date

Sample Description Reference

SS-01-0002 0 to 2 9/10/12 Brown silt and fine sand, trace coarse 

sand, clay, and fine and coarse gravel. 

Dry.

Ref. 26, p. 7; Ref. 

29, p. 27

SS-02-0002 0 to 2 9/10/12 Gray silt with little fine sand, trace 

coarse sand. Moist.

Ref. 26, p. 7; Ref. 

29, p. 28

Background soil samples were submitted to CLP-participating laboratories for analysis of PCBs 

in accordance with CLP Organic SOW SOM01.2 [Ref. 26, p. 7; Ref. 29, pp. 27, 28; Ref. 30, p 1; 

Ref. 31; Ref. 33, p. 1; Ref. 34, p. 1; Ref. 38, p. 1]. HSNE Chemists not involved with the sample 

collection performed a Tier II level data validation of the analytical results in accordance with 

the Region 1 – EPA New England Data Validation Functional Guidelines for Evaluating 

Environmental Analyses [Ref. 32; Ref. 33, p. 1; Ref. 34, p. 1; Ref. 38, p. 1]. The Chain of 

Custody forms are included as Reference No. 30. The CLP-provided analytical data sheets are 

provided in References 33, 34, and 38. Field notes and field data collection summaries are 

presented in Reference 26, and Reference 29, respectively. Table 9 below presents the 

background soil sample results. 
Source Characterization 

Source No. 2 

Keddy Mill HRS Documentation Record 

MEN000106078 32

Table 9 - Hazardous Substances Associated with Background Soil Samples

Sample ID Hazardous 

Substance

Bias Hazardous Substance 

Concentration

Sample-Adjusted 

CRQL

Reference

SS-01-0002 Aroclor-1242 None 38 U ug/kg 38 ug/kg Ref. 33, p 27; 

Ref. 44, pp. 1-

3; Ref. 63, p. 

17

SS-01-0002 Aroclor-1248 None 38 U ug/kg 38 ug/kg Ref. 33, p 27; 

Ref. 44, pp. 1-

3; Ref. 63, p. 

17

SS-02-0002 Aroclor-1242 None 39 U ug/kg 39 ug/kg Ref. 33, p 27; 

Ref. 44, pp. 1-

4; Ref. 63, p. 

18

SS-02-0002 Aroclor-1248 None 39 U ug/kg 39 ug/kg Ref. 33, p 27; 

Ref. 44, pp. 1-

4; Ref. 63, p. 

18

SS-02-0002 Aroclor-1254 None 39 U ug/kg 39 ug/kg Ref. 33, p 27; 

Ref. 44, pp. 1-

4; Ref. 63, p. 

18

Notes: 

CRQL = Contract Required Quantitation Limit 

U = Substance was analyzed for, but not detected and the reported value is the Sample Quantitation Limit 

(SQL) (i.e., Sample Adjusted CRQL). No bias assigned to U qualified data. 

ug/kg = micrograms per kilogram 

Sample-adjusted CRQLs are equivalent to HRS CRQLs as the adjusted (due to moisture, matrix, dilution, etc.) 

limits are based on the CLP CRQLs. In this instance, the sample-adjusted CRQLs are equivalent to sample 

quantitation limits [Ref. 64]. 

Aroclors-1242, 1248, and 1254 were not detected in background soil samples at concentrations 

exceeding their respective Sample-Adjusted Contract-Required Quantitation Limit (CRQL) 

(Sample Quantitation Limit). Therefore Aroclors-1242, 1248, and 1254 are considered above 

background levels, so defined when the source soil sample concentration equals or exceeds the 

background sample-adjusted CRQL [Ref. 1, Table 2-3, p. 51589].

- Source Samples

Surface soil samples listed in Table 10 below were collected during the 2012 EPA SI. Figure 4 

of this HRS Documentation Record provides the sample locations. The samples were collected 

in accordance with the approved Field Task Work plan dated 10 July, 2012 [Ref. 28, pp. 23, 25-

26, 36-37]. 
Source Characterization 

Source No. 2 

Keddy Mill HRS Documentation Record 

MEN000106078 33

Table 10 – Surface Soil Sample Descriptions

Sample ID

Sample 

Depth

(feet bgs)

Sample 

Date Sample Description References

SS-08-0002 0 to 2 9/10/12

Top foot - Dark brown silt and coarse to medium sand, little 

gravel. Moist.

Bottom foot - Brown coarse to medium sand, trace silt, trace 

fine gravel. Moist.

Ref. 26, p. 9; 

Ref. 29, p. 34

SS-09-0002 0 to 1 9/11/12 Dark brown coarse to medium sand, little silt, little medium to 

fine gravel. Dry.

Ref. 26, p. 13; 

Ref. 29, p. 35

SS-DUP01-

0002 0 to 1 9/11/12 Field duplicate sample of SS-09-0002.

Ref. 26, p. 13; 

Ref. 29, p. 35

SS-10-0002 0 to 1.5 9/10/12

Light brown/tan fine sand, trace medium sand and trace silt. 

Glass observed in sample. Sample exhibited a slight petroleum 

odor and appeared to be more-cohesive than would be expected 

of a sand matrix. Dry.

Ref. 26, p. 9; 

Ref. 29, p. 36

SS-11-0002 0 to 2 9/10/12 Brown silt and fine sand, trace coarse sand. Moist. Ref. 26, p. 9; 

Ref. 29, p. 37

SS-12-0002 0 to 0.7 9/11/12 Brown fine sand, little silt, trace coarse sand, trace fine gravel. 

Dry.

Ref. 26, p. 10; 

Ref. 29, p. 38

SS-13-0002 0 to 1 9/11/12 Dark brown fine sand, little silt, trace coarse sand and trace 

fine gravel. Brick was noted in the sample. Moist.

Ref. 26, p. 10; 

Ref. 29, p. 39

SS-14-0002 0 to 1 9/11/12 Dark brown fine to medium sand, little coarse sand, trace silt, 

trace fine gravel. Slag material was noted in the sample. Dry.

Ref. 26, p. 11; 

Ref. 29, p. 40

SS-15-0002 0 to 2 9/11/12

Dark brown fine sand, little silt, trace medium and coarse sand, 

trace fine gravel. Slag was noted in the sample between one 

and two feet bgs. Moist.

Ref. 26, p. 11; 

Ref. 29, p. 41

SS-17-0002 0 to 1.5 9/11/12

Dark brown fine to medium sand, little silt, trace coarse sand, 

trace fine and coarse gravel. Brick and wool-like fabric noted 

in the sample. Moist.

Ref. 26, pp. 

11, 12; Ref. 

29, p. 43

SS-18-0002 0 to 2 9/11/12 Brown fine sand, little medium sand, little silt, trace coarse 

sand, trace fine and coarse gravel. Dry.

Ref. 26, p. 11; 

Ref. 29, p. 44

SS-19-0002 0 to 2 9/14/12

Dark brown fine to medium sand, little coarse sand, trace silt, 

trace fine and coarse gravel. Metal material was noted in the 

sample. Dry.

Ref. 26, p. 20; 

Ref. 29, p. 45

SS-DUP02-

0002 0 to 2 9/14/12 Field duplicate sample of SS-19-0002.

Ref. 26, p. 20; 

Ref. 29, p. 45

SS-20-0002 0 to 1 9/14/12 Brown fine to medium sand, little silt, trace coarse sand, trace 

fine gravel. Some slag material noted in the sample. Dry.

Ref. 26, p. 20; 

Ref. 29, p. 46

SS-21-0002 0 to 1.5 9/11/12 Brown fine to coarse sand, trace silt, trace fine and coarse 

gravel. Dry.

Ref. 26, p. 11; 

Ref. 29, p. 47

SS-22-0002 0 to 2 9/11/12

0-1 feet bgs - Dark brown fine to coarse sand, little silt, trace 

fine and coarse gravel. Slag noted in the sample. Dry.

1-1.5 feet bgs - Red-brown fine to coarse sand, little silt, trace 

fine gravel. Slag noted in the sample. Dry.

1.5-2 feet bgs - tan/gray fine to medium sand with some clay. 

Moist.

Ref. 26, p. 11; 

Ref. 29, p. 48

SS-23-0002 0 to 1 9/11/12

Light brown fine sand, little silt, trace medium and coarse sand, 

trace fine and coarse gravel. Pieces of burnt wood noted in 

sample.

Ref. 26, p. 11; 

Ref. 29, p. 49

Notes: 

bgs - Below ground surface 

Soil sample SS-16-0002 was collected from an area at the southernmost portion of the property and is not part of 
Source Characterization 

Source No. 2 

Keddy Mill HRS Documentation Record 

MEN000106078 34

Source No. 2.

Surface soil samples were submitted to CLP-participating laboratories for analysis of PCBs in 

accordance with CLP Organic SOW SOM01.2 [Ref. 26, pp. 7-13, 20; Ref. 29, pp. 29-49; Ref. 

30, pp. 1-3, 6-9, 12, 13; Ref. 31]. Chemists not involved with the sample collection performed a 

Tier II level validation of the analytical results in accordance with the Region 1 – EPA New 

England Data Validation Functional Guidelines for Evaluating Environmental Analyses [Ref. 

32; Ref. 33, p. 1; Ref. 34, p. 1; Ref. 38, p. 1]. The Chain of Custody forms are included as 

Reference No. 30. The CLP-provided analytical data sheets are provided in References 33, 34, 

and 38. Field notes and field data collection summaries are presented in Reference 26, and 

Reference 29, respectively. Table 11 below presents the surface soil sample results. 

For the purposes of Source No. 2 evaluation, the analytical results of these 17 source samples 

confirm the presence of PCB mixtures Aroclor 1242, Aroclor-1248, and Aroclor-1254 [Ref. 33, 

p. 26; Ref. 34, p. 34; Ref. 38, pp. 22, 23; Ref. 44, pp. 4, 5] (see Table 11 below). Source No. 2 

has been documented to contain hazardous substances in accordance with the HRS [Ref. 1, p. 

51587]. 

Table 11 - Hazardous Substances Associated with Source No. 2

Sample ID Hazardous 

Substance Bias Hazardous Substance Concentration

Sample-Adjusted 

CRQL References

SS-08-0002 Aroclor-1248 None 140 ug/kg 38 ug/kg Ref. 33, p. 

27; Ref. 44, 

pp. 1-4; Ref. 

63, p. 19

SS-08-0002 Aroclor-1254 None 150 ug/kg 38 ug/kg Ref. 33, p. 

27; Ref. 44, 

pp. 1-4; Ref. 

63, p. 19

SS-09-0002 Aroclor-1242 None 110,000 J ug/kg 15,000 ug/kg Ref. 34, p. 

36; Ref. 44, 

pp. 1-4; Ref. 

63, p. 21

SS-DUP01-0002 Aroclor-1242 None 100,000 J ug/kg 14,000 ug/kg Ref. 34, p. 

37; Ref. 44, 

pp. 1-54; Ref. 

63, p. 40

SS-10-0002 Aroclor-1248 None 110 J ug/kg 38 ug/kg Ref. 33, p. 

28; Ref. 44, 

pp. 1-4; Ref. 

63, p. 22

SS-10-0002 Aroclor-1254 None 420 ug/kg 38 ug/kg Ref. 33, p. 

28; Ref. 44, 

pp. 1-4; Ref. 

63, p. 22

SS-11-0002 Aroclor-1254 None 55 J ug/kg 38 ug/kg Ref. 33, p. 

28; Ref. 44, 

pp. 1-5; Ref. 

63, p. 23
Source Characterization 

Source No. 2 

Keddy Mill HRS Documentation Record 

MEN000106078 35

Table 11 - Hazardous Substances Associated with Source No. 2

Sample ID Hazardous 

Substance Bias Hazardous Substance Concentration

Sample-Adjusted 

CRQL References

SS-12-0002 Aroclor-1254 None 150 ug/kg 36 ug/kg Ref. 34, p. 

36; Ref. 44, 

pp. 1-5; Ref. 

63, p. 24

SS-13-0002 Aroclor-1248 None 1,900 ug/kg 370 ug/kg Ref. 34, p. 

36; Ref. 44, 

pp. 1-5; Ref. 

63, p. 26

SS-13-0002 Aroclor-1254 None 4,000 ug/kg 370 ug/kg Ref. 34, p. 

36; Ref. 44, 

pp. 1-5; Ref. 

63, p. 26

SS-14-0002 Aroclor-1254 None 1,900 ug/kg 370 ug/kg Ref. 34, p. 

36; Ref. 44, 

pp. 1-5; Ref. 

63, p. 28

SS-15-0002 Aroclor-1254 None 640 J ug/kg 190 ug/kg Ref. 34, p. 

36; Ref. 44, 

pp. 1-5; Ref. 

63, p. 30

SS-17-0002 Aroclor-1254 None 100 J ug/kg 40 ug/kg Ref. 34, p. 

37; Ref. 44, 

pp. 1-5; Ref. 

63, p. 31

SS-18-0002 Aroclor-1254 None 67 ug/kg 36 ug/kg Ref. 34, p. 

37; Ref. 44, 

pp. 1-5; Ref. 

63, p. 32

SS-19-0002 Aroclor-1254 None 90 ug/kg 36 ug/kg Ref. 38, p. 

22; Ref. 44, 

pp. 1-4; Ref. 

63, p. 33

SS-DUP02-0002 Aroclor-1254 None 86 ug/kg 37 ug/kg Ref. 38, p. 

23; Ref. 44, 

pp. 1-4; Ref. 

63, p. 41

SS-20-0002 Aroclor-1254 None 76 ug/kg 39 ug/kg Ref. 38, p. 

23; Ref. 44, 

pp. 1-4; Ref. 

63, p. 34

SS-21-0002 Aroclor-1254 None 160 J ug/kg 35 ug/kg Ref. 34, p. 

37; Ref. 44, 

pp. 15; Ref. 

63, p. 35
Source Characterization 

Source No. 2 

Keddy Mill HRS Documentation Record 

MEN000106078 36

Table 11 - Hazardous Substances Associated with Source No. 2

Sample ID Hazardous 

Substance Bias Hazardous Substance Concentration

Sample-Adjusted 

CRQL References

SS-22-0002 Aroclor-1254 None 61 J ug/kg 41 ug/kg Ref. 34, p. 

37; Ref. 44, 

pp. 1-5; Ref. 

63, p. 36

SS-23-0002 Aroclor-1254 None 780 ug/kg 170 ug/kg Ref. 34, p. 

37; Ref. 44, 

pp. 1-5; Ref. 

63, p. 37

Notes: 

CRQL = Contract Required Quantitation Limit 

J = Reported value is an estimate based upon an evaluation of quality control parameters. An analysis of 

potential bias associated with samples was performed and is presented as part of Reference 44. Although 

some of the presented data is J-qualified, it does not exhibit a bias. 

ug/kg = micrograms per kilogram 

Sample-adjusted CRQLs are equivalent to HRS CRQLs as the adjusted (due to moisture, matrix, dilution, etc.) 

limits are based on the CLP CRQLs. In this instance, the sample-adjusted CRQLs are equivalent to sample 

quantitation limits [Ref. 64]. 

Soil sample SS-16-0002 did not contain detections of PCBs, and is not included in this table 

List of Hazardous Substances Associated with Source No. 2

Aroclor-1242 

Aroclor-1248 

Aroclor-1254 

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY 

Site observations, sample collection logs, and previous soil borings do not indicate the presence 

of a maintained engineered barrier cover or runoff control management system [Ref. 20, pp. 45, 

46; Ref. 29, pp. 1-5, 32, 33]. Therefore, a containment value of 10 as noted in Table 12 below is 

assigned for the surface water pathway [Ref. 1, Table 4-2, pp. 51609, 51610]. 

Table 12 - Hazardous Substances Available to Pathways

Containment Description Containment 

Factor Value

Reference

Gaseous Release to Air: Not Evaluated Not Scored

Particulate Release to Air: Not Evaluated Not Scored

Release to Ground Water: Not Evaluated Not Scored

Release to Surface Water via Overland Flow and/or Flood: No 

maintained engineered barrier or runoff management system is 

present to control this source

10 Ref. 1, p. Table 4-2, pp. 

51609, 51610; Ref. 29, pp. 

34-49

2.4.2 HAZARDOUS WASTE QUANTITY 

The hazardous waste quantity for Source No. 2 was assigned based on the area factor value for 

 ource Type “Contaminated oil” [Ref. 1, Table -5, p. 51591]. Due to the lack of available 

information (i.e., hazardous waste manifests, waste analytical results or characteristics, discharge 
Source Characterization 

Source No. 2 

Keddy Mill HRS Documentation Record 

MEN000106078 37

records, etc.), neither the Hazardous Constituent Quantity nor the Hazardous Wastestream 

Quantity were evaluated. 

2.4.2.1.1 Hazardous Constituent Quantity 

Description

Information on the quantity (in pounds) of individual hazardous substances in Source No. 2 is 

not available to evaluate Tier A, hazardous constituent quantity. The number of samples 

collected is not statistically representative of the range of concentrations throughout the source. 

Therefore, it is not possible to adequately determine a hazardous constituent quantity for Source 

No. 2 with reasonable confidence [Ref. 1, Section 2.4.2.1.1, p. 51591]. Scoring proceeds to the 

evaluation of Tier B, hazardous wastestream quantity [Ref. 1, Section 2.4.2.1.2, p. 51591]. 

Hazardous Constituent Quantity value assigned = Not Scored

2.4.2.1.2 Hazardous Wastestream Quantity 

Description

The information on the total mass of all hazardous wastestreams and CERCLA pollutants and 

contaminants for Source No. 2 is not sufficient to evaluate Tier B, hazardous wastestream 

quantity. There is insufficient information that documents wastestream disposal; therefore, it is 

not possible to adequately determine a reasonably complete hazardous wastestream quantity for 

Source No. 2 [Ref. 1, Section 2.4.2.1.2, p. 51591]. Scoring proceeds to the evaluation of Tier C, 

volume [Ref. 1, Section 2.4.2.1.3, p. 51591]. 

Hazardous Wastestream Quantity value assigned = Not Scored

2.4.2.1.3 Volume 

Description

The depth of the Source No. 2 is not known and the extent of the source has not been 

determined. The information available is not sufficient to evaluate Tier C, volume, as required 

by the HRS [Ref. 1, Section 2.4.2.1.3, p. 51591]. Scoring proceeds to the evaluation of Tier D, 

area [Ref. 1, Section 2.4.2.1.4, p. 51591]. 

Volume value assigned = 0 

2.4.2.1.4 Area 

Description

Based upon the analytical results of the source samples, observations of the materials within 

Source No. 2, and the presence of previous investigation data indicating that PCB contamination 

is present throughout the Source No. 2 area, the areal extent of this source is defined using the 
Source Characterization 

Source No. 2 

Keddy Mill HRS Documentation Record 

MEN000106078 38

perimeter made up of 13 surface soil sample locations (refer to Figure 4 of this HRS 

Documentation Record) [Ref. 21, pp. 10-16, 19]. As presented on Table 13 below, Source No. 2 

occupies an area of approximately 63,613 square feet [Ref. 43]. 

Table 13 – Area

Source Type Units (Square feet) Reference

Contaminated Soil 63,613 Ref. 43; Figure 2

To assign a Hazardous Waste Quantity value to a ource Type “Contaminated oil”, the area in 

square feet is divided by 34,000 [Ref. 1, Table 2-5, p. 51591]. 

Sum in square feet: 63,613 

Equation for Assigning Value [Ref. 1, Table 2-5, p. 51591]: 63,613 ÷ 34,000 = 1.87 

Area value assigned = 1.87

2.4.2.1.5 Source Hazardous Waste Quantity Value

The HWQ for Source No. 2 is assigned based on the Area Factor Value (1.87) [Ref. 1, Table 2-5, 

p. 51591].

Source No. 2 Hazardous Waste Quantity Value = 1.87
Source Characterization 

Summary 

Keddy Mill HRS Documentation Record 

MEN000106078 39

Table 14 - Summary of Source Descriptions

Source

No.

Source 

Hazardous 

Waste 

Quantity 

Value

Source 

Hazardous 

Constituent 

Quantity 

Complete?

(Y/N)

Containment Factor Value by Pathway

Ground

Water (Ref 

1, Table 3-2)

Surface Water Air

Overland 

Flow/Flood (Ref 

1, Table 4-2)

GW to SW 

Migration

Gas (Ref 1, 

Table 6-3)

Particulate (Ref 

1, Table 6-9)

1 0.448 N Not Scored 10 Not Scored Not Scored Not Scored

2 1.87 N Not Scored 10 Not Scored Not Scored Not Scored

Notes: 

GW – Ground Water 

No. – Number 

N – No

SW – Surface Water 

Y – Yes

Total Source Hazardous Waste Quantity Value: 2.318 

Other Possible Sources Not Scored:

PCB Releases Resulting in Contaminated Building Materials 

During sampling activities on the Keddy Mill property in July 2005, property owner contractors 

discovered that as much as 40 gallons of PCB-containing oil was released to the concrete floor of 

the Keddy Mill property buildings. The release was reported to the MEDEP [Ref. 24, pp. 1, 2]. 

Subsequent sampling of interior building media including: surface wipes of building interior 

surfaces, sludge, interior soil, wood, and debris indicated that the PCB contamination was not 

limited to the known PCB release area, but was widespread throughout the interior of the Keddy 

Mill property buildings [Ref. 42, pp. 9, 10, 15-17, 20, 21]. 

A cleanup action was conducted in 2010 as part of the SICP Phase I [Ref. 53, p. 3]. The 

implemented cleanup action involved: the removal and disposal of sludge, dirt, and oily debris 

from the building floors; the removal and disposal of heavy oil coating from building floors, 

walls, and stationary equipment; cleaning and capping of fuel supply piping; and placement of 

polyethylene and approximately 2 inches of clean sand fill over exposed soils that may contain 

PCBs in broken areas of concrete [Ref. 53, p. 3]. Subsequent concrete sampling was performed 

by MEDEP which indicated that PCBs were present in the concrete floors of each of the 

buildings and on all levels [Ref. 21, pp. 4, 5]. 

During the 2012 SI property reconnaissance, the buildings were observed to be in poor condition 

with broken windows and cracked, scaled, and broken concrete floors. Puddles were observed in 

the building basement, which were likely the result of precipitation entering the building through 

the broken windows [Ref. 26, pp. 1-4]. Based on the presence of PCBs in the building materials 

and the condition of the building, the contaminants are able to migrate from the building interior 

to underlying ground water and surface water (through holes in the concrete floor). 
Surface Water Migration Pathway – Overland Flow

General Considerations

Keddy Mill HRS Documentation Record 

MEN000106078 40

4.0 SURFACE WATER MIGRATION PATHWAY 

4.1 OVERLAND/FLOOD MIGRATION COMPONENT 

 

4.1.1 GENERAL CONSIDERATIONS 

The Keddy Mill property is located adjacent to the Presumpscot River and the Little Falls Dam. 

The property is within the Presumpscot River drainage basin [Ref. 12, pp. 10, 18; Ref. 36, pp. 

85, 86]. A portion of the Presumpscot River downstream of the Little Falls Dam flows beneath 

the western portion of the Manufacturing and Office Building basement [Ref. 12, p. 23; Ref. 26, 

p. 3]. 

The Keddy Mill property generally slopes south and west toward the Presumpscot River [Ref. 5, 

p. 1; Ref. 26, pp. 1, 3, 20]. 

During the EPA SI reconnaissance of the Keddy Mill property, a small intermittent stream was 

observed flowing southwest and west in a small eroded channel from an area of high elevation in 

the northeastern portion of the property towards lower elevation in the central portion of the 

property where water pooled [Ref. 26, p. 3; Ref. 60, pp. 1, 2]. From the pool, water flowed down 

a loading dock ramp, through a boarded-up door, and into the western portion of the 

Manufacturing and Office Building basement [Ref. 26, p. 3; Ref. 60, p. 3]. Water within the 

basement of the former Manufacturing and Office Building discharged to the Presumpscot River 

under the building, through holes in the concrete floor [Ref. 26, p. 3; Ref. 60, p. 3]. During the 

EPA SI reconnaissance, silt and sand deposits were observed within the basement in the area of 

the holes in the concrete floor. These deposits were presumed to be the result of the water 

entering the basement [Ref. 26 p. 3; Ref. 27, p. 21]. 

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component 

The hazardous substance migration pathway includes both the overland segment and the in-water 

segment that hazardous substances would take as they migrate away from sources. The overland 

segment begins at the source and proceeds down slope to the probable point of entry (PPE) to 

surface water (refer to Figure 2 of this HRS Documentation Record). The in-water segment at 

the PPE continues in the direction of flow [Ref. 1, Section 4.1.1.1, p. 51605]. 

Surface water runoff from the western portion of Source No. 1 flows south and southwest for 

approximately 210 feet to probable point of entry 1 (PPE 1) into the Presumpscot River [Ref. 60, 

pp. 4, 6]. Surface water runoff from the central and eastern portions of Source No. 1 flows south 

into an intermittent stream, and then west/southwest about 270 feet to PPE No. 2. PPE No. 2 is 

located at a hole in the concrete floor within the Manufacturing and Office Building basement 

that drains directly to the underlying Presumpscot River [Ref. 60, pp. 1-4, 6]. Surface water 

runoff from the northern portion of Source No. 2 flows north into the intermittent stream, and 

then west/southwest about 300 feet to PPE No. 2 [Ref. 60, pp 1-3, 5, 6]. Surface water runoff 

from the southern portion of Source No. 2 flows west/southwest about 80 feet to PPE No. 3 into 

the Presumpscot River [Ref. 60, pp. 5, 6]. 
Surface Water Migration Pathway – Overland Flow 

General Considerations 

Keddy Mill HRS Documentation Record 

MEN000106078 41

4.1.1.2 Target Distance Limit 

The most-upstream PPE for the Keddy Mill property is PPE No. 1 associated with Source No. 1. 

The most downstream PPE is PPE No. 3, associated with Source No. 2. 

None of the sediment samples collected as part of the 2012 EPA SI were from areas beyond 15 

miles downstream of the most-downstream PPE No. 3 [Ref. 29, pp. 6-26; Ref. 27, pp. 8, 17, 18]. 

Therefore, as an observed release is not documented beyond 15 miles from the most-downstream 

PPE (PPE No. 3), as shown on Figure 5, the Target Distance Limit (TDL) extends 15 miles 

downstream of the PPE No. 3 [Ref. 1, p. Section 4.1.1.2, p. 51905].

The entirety of the 15-mile TDL is contained within the Presumpscot River (Figure 5) [Ref. 39].
Surface Water Migration Pathway – Overland Flow 

Likelihood of Release 

Keddy Mill HRS Documentation Record 

MEN000106078 42

4.1.2.1 Likelihood of Release 

4.1.2.1.1 Observed Release 

Chemical Analysis – 2012 Sediment Samples

Background Concentrations

As summarized on Table 15 below, two background sediment samples (SED-01 and SED-02) 

were collected as part of the EPA SI [Ref. 26, pp. 20, 21; Ref. 29, pp. 6-8]. The background 

sediment samples were collected from 0 to 2 feet bgs upstream of the PPEs [Ref. 26, pp. 20, 21; 

Ref. 29, pp. 6-8] (see Figure 6 of this HRS documentation record). The background sample 

locations were selected to represent each of the different sediment depositional environments 

encountered along the Presumpscot River during the sampling. These areas include portions of 

the Presumpscot River behind dams and within the Presumpscot River adjacent to wetlands. The 

background sediment samples were collected of the entire sediment core between 0 and 2 feet 

below the mud line. These background sediment samples were collected in accordance with the 

EPA-approved Field Task Work Plan dated July 10, 2012 [Ref. 28]. Table 16 below provides 

further description of the background sediment samples collected. 

Table 15 - Background Sediment Sample Locations

Sample 

ID

Sample 

Matrix Sample Location

Distance 

Upstream of 

PPE No. 1

Depth Below 

Mud Line 

(feet)

Date References

Within the Presumpscot River - Upstream of Dam Impoundment

SED-01 Sediment

Within the Presumpscot 

River, immediately 

upstream of the Gambo 

Dam (approximately 1.5 

miles upstream of the 

Keddy Mill property).

1.5 miles 0 to 2 9/14/12

Ref. 26, p. 21;

Ref. 27, p. 8; 

Ref. 29, p. 6;

Ref. 45, pp. 1, 3

Within the Presumpscot River - Adjacent to Wetland Frontage

SED-02 Sediment

Within the Presumpscot

River adjacent to an area 

of wetland frontage 

upstream of the Route 202

bridge.

420 feet 0 to 2 9/14/12

Ref. 26, p. 20;

Ref. 27, p. 8; 

Ref. 29, p. 7

Ref. 45, pp. 1, 2

Ref. 61, pp. 2, 5

Notes: 

No. = Number 

PPE = Probable point of Entry

Table 16 - Background Sediment Sample Descriptions

Sample ID Sample Description References

Within the Presumpscot River – Upstream of Dam Impoundment

SED-01 Brown to gray silt, trace fine sand, trace fine gravel. Glass observed in the sample. Ref. 29, p. 6

Within the Presumpscot River - Adjacent to Wetland Frontage

SED-02 Brown/tan fine to medium sand, trace silt. Some organic (wood) materials noted in 

sample. Ref. 29, p. 7

Notes: 
Surface Water Migration Pathway – Overland Flow 

Likelihood of Release 

Keddy Mill HRS Documentation Record 

MEN000106078 43

The background sediment samples were submitted to a CLP-participating laboratory for PCBs in 

accordance with CLP Organic SOW SOM01.2 [Ref. 26, pp. 20, 21; Ref. 29, pp. 6-8; Ref. 30, p. 

10; Ref. 31; Ref. 33, p. 1; Ref. 34, p. 1; Ref. 38, p. 1]. The background sediment samples were 

also analyzed for Total Organic Carbon (TOC) via Lloyd Kahn method as an additional means of 

comparison to contaminated sediment samples [Ref. 41, pp. 1, 3].

Chemists not involved with the sample collection performed a Tier II level data validation of the 

CLP-provided sediment sample analytical results in accordance with the Region 1 – EPA New 

England Data Validation Functional Guidelines for Evaluating Environmental Analyses [Ref. 

32; Ref. 33, p. 1; Ref. 34, p. 1; Ref. 38, p. 1]. These same chemists also performed a modified 

Tier I level data validation of the sediment sample TOC analytical results in accordance with the 

Region 1 – EPA New England Data Validation Functional Guidelines for Evaluating 

Environmental Analyses [Ref. 32; Ref. 33, p. 1; Ref. 34, p. 1; Ref. 38, p. 1]. The Chain of 

Custody forms are included as References 30 and 40. The CLP-provided analytical data sheets 

are provided in References 33, 34, and 38. The TOC analytical laboratory data sheets are 

included in Reference 41 [Ref. 41]. Field notes and field data collection summaries are 

presented in Reference 26, and Reference 29, respectively. 

As analytical results did not detect PCBs above sample-adjusted Contract Required Quantitation 

Limits (CRQL) in background sediment samples, Table 17 below presents the sample 

quantitation limits (SQLs) and sample-adjusted CRQLs for Aroclor-1248 and Aroclor-1254. 

Table 17 - Hazardous Substances Associated with Background Sediment Samples

Sample 

ID

Hazardous 

Substance

Bias Hazardous Substance 

Concentration

Sample-Adjusted 

CRQL

Reference

Within the Presumpscot River – Upstream of Dam Impoundment

SED-01 Aroclor-1248 None 84 U ug/kg 84 ug/kg Ref. 34, p. 35; Ref. 

44, pp. 1, 2; Ref. 

63, p. 43

SED-01 Aroclor-1254 None 84 U ug/kg 84 ug/kg Ref. 34, p. 35; Ref. 

44, pp. 1, 2; Ref. 

63, p. 43

Within the Presumpscot River - Adjacent to Wetland Frontage

SED-02 Aroclor-1248 None 45 U ug/kg 45 ug/kg Ref. 34, p. 35; Ref. 

44, pp. 1, 2; Ref. 

63, p. 44

SED-02 Aroclor-1254 None 45 U ug/kg 45 ug/kg Ref. 34, p. 35; Ref. 

44, pp. 1, 2; Ref. 

63, p. 44

Notes: 

CRQL = Contract Required Quantitation Limit 

ID = Identification 

U = Substance was analyzed for, but not detected and the reported value is the Sample Quantitation Limit 

(SQL) (i.e., Sample Adjusted CRQL). No bias assessment needed for U qualified data. 

ug/kg = micrograms per kilogram 

Sample-adjusted CRQLs are equivalent to HRS CRQLs as the adjusted (due to moisture, matrix, dilution, etc.) 

limits are based on the CLP CRQLs. In this instance, the sample-adjusted CRQLs are equivalent to sample 

quantitation limits [Ref. 64]. 
Surface Water Migration Pathway – Overland Flow 

Likelihood of Release 

Keddy Mill HRS Documentation Record 

MEN000106078 44

Contaminated Samples

Between September 12 through 14, 2012, four sediment samples were collected from the 

Presumpscot River as part of the EPA SI [Ref. 27, pp. 17, 18; Ref. 29, pp. 9, 10, 12, 20]. The 

samples were collected at depths ranging from 0 to 2 feet below sediment mud line (refer to 

Figure 6 of this HRS Documentation Record) [Ref. 29, pp. 9, 10, 12, 20]. The samples were 

collected in accordance with the approved Field Task Work plan dated 10 July, 2012 [Ref. 28, 

pp. 24, 26, 37-42]. 

Table 18 below provides a summary of the sediment sample locations and Table 19 provides a 

summary of the samples. Table 19 below provides further description of the contaminated 

sediment samples collected. 

Table 18 – Contaminated Sediment Sample Location Descriptions

Sample 

ID

Sample 

Matrix Sample Location

Distance 

Downstream of 

PPE No. 1

Depth Below 

Mud Line 

(feet)

Sample 

Date References

Within the Presumpscot River – Upstream of Dam Impoundment

SED-04 Sediment

Within the Presumpscot 

River, upstream of Little 

Falls Dam; adjacent to 

concrete structure at PPE 

No. 1

10 feet 0 to 1 9/14/12 Ref. 29, p. 9; Ref 

45, p. 1

SED-16 Sediment

Within the Presumpscot 

River, downstream of the 

Keddy Mill property along 

the western river bank in an 

area of apparent 

sedimentation, immediately 

upstream of the Mallison 

Falls Dam.

3,186 feet 0 to 0.5 9/12/12 Ref. 29, p. 20; 

Ref. 45, p. 1

Within the Presumpscot River - Adjacent to Wetland Frontage

SED-05 Sediment

Within the Presumpscot 

River, downstream of the 

Keddy Mill property 

buildings along the western 

river bank, adjacent to 

wetland frontage, at a point 

where the river exits from 

under the building at PPE 

No. 3.

378 feet 0 to 2 9/13/12 Ref. 29, p. 10; 

Ref. 45, p. 1

SED-07 Sediment

Within the Presumpscot 

River, downstream of the 

Keddy Mill buildings along 

the western river bank at the 

downstream end of an area 

of wetland frontage

551 feet 0 to 1 9/13/12 Ref. 29, p. 12; 

Ref. 45, p. 1

Notes: 

PPE = Probable point of Entry 

Note that PPE No. 2 is located beneath the former Keddy Mill property buildings and was inaccessible. 

Due to sampler safety concerns, sediment sample SED-16 was collected from the top 0.5 feet of sediment using 

clamshell sampler. 
Surface Water Migration Pathway – Overland Flow 

Likelihood of Release 

Keddy Mill HRS Documentation Record 

MEN000106078 45

The contaminated sediment samples were collected of the entire sediment core between the mud line and the depths 

identified in the table above. 

Table 19 – Contaminated Sediment Sample Descriptions

Sample ID Sample Description References

Within the Presumpscot River – Upstream of Dam Impoundment

SED-04 Brown fine to medium sand, little silt, trace coarse sand, trace fine and 

coarse gravel. Brick material noted in the sample. 

Ref. 27, p. 17; Ref. 

29, p. 9

SED-16 Gray to brown silt with some fine sand, trace gravel. Ref. 27, p. 18; Ref. 

29, p. 20

Within the Presumpscot River - Adjacent to Wetland Frontage

SED-05

Brown fine sand, some silt, some medium sand, trace coarse sand, some 

organic debris (leaves and wood). A petroleum odor was associated 

with this sample, and a sheen was observed on the water that had 

separated in the sample mixing bowl.

Ref. 27, p. 17; Ref. 

29, p. 10

SED-07

Dark brown silt some fine sand. Organic matter observed in the sample. 

Plastic was observed in the sample as was slag material. A large 

amount of slag was observed both in and out of the river in this area.

Ref. 27, p. 18; Ref. 

29, p. 12

The contaminated sediment samples were submitted to a CLP-participating laboratory for 

analysis of PCBs in accordance with CLP Organic SOW SOM01.2 [Ref. 26, pp. 15, 18, 20; Ref. 

27, pp.17, 18; Ref. 29, pp. 9-12, 20; Ref. 30, pp. 4, 10, 11; Ref. 31]. As an additional means of 

comparison between the background sediment samples and the contaminated sediment samples, 

the contaminated sediment samples were also analyzed for TOC via Lloyd Kahn method [Ref. 

41, p. 1].

Chemists not involved with the sample collection performed a Tier II level data validation of the 

CLP-provided sediment sample analytical results in accordance with the Region 1 – EPA New 

England Data Validation Functional Guidelines for Evaluating Environmental Analyses [Ref. 

32; Ref. 33, p. 1; Ref. 34, p. 1; Ref. 38, p. 1]. These chemists also performed a modified Tier I 

level data validation of the sediment sample TOC analytical results in accordance with the 

Region 1 – EPA New England Data Validation Functional Guidelines for Evaluating 

Environmental Analyses [Ref. 32; Ref. 33, p. 1; Ref. 38, p. 1]. The Chain of Custody forms are 

included as References 30 and 40. The CLP-provided analytical data sheets are provided in 

References 31 and 38. The TOC analytical laboratory data sheets are included in Reference 41. 

Field notes and field data collection summaries are presented in Reference 26, and Reference 29, 

respectively. 

The contaminated sediment samples were collected from similar environments within the 

Presumpscot River to those associated with the background samples. Both the background 

samples and contaminated samples were collected during the same sampling event, and in 

accordance with the same sampling procedures. Contaminated samples SED-04 and SED-16 

were collected upstream of dams along the Presumpscot River, and are compared to background 

sediment sample SED-01, that was also collected upstream of a dam within the Presumpscot 

River. Contaminated sediment samples SED-05 and SED-07 were collected from the 

Presumpscot River in areas adjacent to wetland frontage, and are compared to background 

sediment sample SED-02, that was collected from the Presumpscot River adjacent to wetlands 

located upstream of the Keddy Mill property [Ref. 26, pp. 20, 21, Ref. 27, p. 8, Ref. 29, pp. 6, 7, 

9, 10, 12, 16; Ref. 45, pp. 1, 2; Ref. 61, pp. 2, 5]. PCBs were not detected above detection limits 
Surface Water Migration Pathway – Overland Flow

Likelihood of Release

Keddy Mill HRS Documentation Record 

MEN000106078 46

in either of the background samples (see Table 17). The background sediment samples and 

downstream contaminated sediment samples primarily contained brown, tan/gray fine-grained 

materials (i.e., silt and fine sand) [Ref. 27, pp. 17, 18, Ref. 29, pp. 6, 7, 10, 12]. 

The results of the TOC analyses show the background concentrations and corresponding 

downstream concentrations are generally in the same range [Ref. 41, p. 3].

Table 20 below contains the PCB mixtures Aroclor-1248 and Aroclor-1254 detected in the 

contaminated sediment samples. 

Table 20 - Hazardous Substances Associated with Contaminated Sediment Samples

Sample ID Hazardous 

Substance Bias Hazardous Substance Concentration

Sample-Adjusted 

CRQL Reference

Dam Impoundment Sample

SED-04 Aroclor-1254 None 280 J ug/kg 42 ug/kg Ref. 38, p. 21; 

Ref. 44, pp. 1, 

2, 4; Ref. 63, p. 

46

SED-16 Aroclor-1254 None 87 J ug/kg 52 ug/kg Ref. 33, p. 26; 

Ref. 44, pp. 1, 

2, 4; Ref. 63, p. 

50

In-Water Segment; Adjacent to Wetland Frontage Sample

SED-05 Aroclor-1248 None 1,100 J ug/kg 460 ug/kg Ref. 38, p. 21; 

Ref. 44, pp. 1, 

2, 4; Ref. 63, p. 

48

SED-05 Aroclor-1254 None 2,100 ug/kg 460 ug/kg Ref. 38, p. 21; 

Ref. 44, pp. 1, 

2, 4; Ref. 63, p. 

48

SED-07 Aroclor-1254 None 430 J ug/kg 110 ug/kg Ref. 38, p. 21; 

Ref. 44, pp. 1, 

2, 4; Ref. 63, p. 

49

Notes: 

CRQL = Contract Required Quantitation Limit 

J = Reported value is an estimate based upon an evaluation of quality control parameters. An analysis of 

potential bias associated with samples was performed and is presented as part of Reference 44. Although 

some of the presented data is J-qualified, it does not exhibit a bias. 

Sample-adjusted CRQLs are equivalent to HRS CRQLs as the adjusted (due to moisture, matrix, dilution, etc.) 

limits are based on the CLP CRQLs. In this instance, the sample-adjusted CRQLs are equivalent to sample 

quantitation limits [Ref. 64]. 

Attribution

PCBs refer to mixtures of up to 209 individual chemicals (referred to as congeners) that do not 

occur naturally. “Aroclor” is a trade name for these mixtures. The Aroclor name is followed by 

a four-digit code, where the first two digits refer to type of mixture and the last two digits refer to 

the approximate percent chlorine by weight [Ref. 46, pp. 467, 468]. The manufacture and import 

of PCBs has been banned in the United States since 1977 [Ref. 47, p. 1]. 
Surface Water Migration Pathway – Overland Flow 

Likelihood of Release 

Keddy Mill HRS Documentation Record 

MEN000106078 47

PCBs were used in numerous commercial and industrial applications; however, the specific 

Aroclors detected on the Keddy Mill property, and within the Presumpscot River, are Aroclor1242, Aroclor-1248, and Aroclor-1254. These were commonly used in: capacitors, transformers, 

heat transfer units, vacuum pumps, hydraulic fluids, gas-transmission turbines, rubbers, synthetic 

resins, carbonless papers, adhesives, wax extenders, dedusting agents, inks, cutting oils, pesticide 

extenders, and sealants/caulking compounds [Ref. 46, pp. 493, 494]. 

EPA has identified hydraulic systems, particularly in the steel manufacturing industry, as 

containing PCBs. EPA states that hydraulic systems operate at high pressure and often leak 

[Ref. 58, p. 15]. Several hammer units were observed in the basement of the former Melt 

Building [Ref. 26, p. 3]. It could not be determined if these units were hydraulic. 

Cutting oil also formerly contained PCBs [Ref. 46, p. 494]. Although no cutting tools or similar 

machinery were observed during the April 2012 EPA SI site visit, as a former heavy equipment 

bucket and piping fabrication shop, it is likely that such equipment was utilized on the Keddy 

Mill property to cut down large steel pieces into smaller pieces [Ref. 26; Ref. 65, pp 23, 24]. 

Electric transformers were present on the Keddy Mill property [Ref. 14, pp. 22, 23; Ref. 15, p. 

13]. A release of between 30 and 40 gallons PCB-containing fluid within the Keddy Mill 

buildings from at least one transformer was reported to MEDEP in July 2005 [Ref. 24, p. 1]. 

This PCB contamination, along with documented PCB contamination on the floors and walls 

throughout the Keddy Mill buildings was the subject of a TSCA cleanup action conducted in 

2010 [Ref. 53, pp. 2, 3]. 

No known upstream sources of PCBs are located between the most-upstream background sample 

(SED-01) and the most-downstream contaminated sample (SED-16) [Ref. 62].

The primary land use along the Presumpscot River between the Keddy Mill property and the 

most-downstream sediment sample is either undeveloped or residential [Ref. 48, p. 1]. 

As summarized above, PCBs detected in the Presumpscot River are at least partially attributable 

to Source Nos. 1 and 2 for the following reasons: 

 Samples collected from Source Nos. 1 and 2 contain PCBs (Aroclors) at elevated 

concentrations (refer to Section 2.2 of this HRS Documentation Record) [Ref. 33, pp. 26, 

27, 28; Ref. 34, pp. 34, 35, 36, 37; Ref. 63, pp. 2-7, 10-14, 19, 21-24, 26, 28, 30-37, 40, 

41] 

 No functioning and maintained run-on or run-off management system is in place at 

Source Nos. 1 and 2 to prevent run-off from occurring [Ref. 20, pp. 42, 43; Ref. 29, pp. 

1-5, 32, 33].

 Analytical results for samples collected from the Presumpscot River, which receives 

runoff from Source Nos. 1 and 2, indicate that a release of hazardous substances has 

occurred to the surface water migration pathway (refer to Section 4.1.2.1.1 of this HRS 

documentation record) [Ref. 38, pp. 21, 26; Ref. 63, pp. 46, 48, 49, 50]. 

 The topography of the Keddy Mill property slopes towards the Presumpscot River, and 

evidence of channelized storm water flow through sources and discharging to the river 

was observed [Ref. 5, p. 1; Ref. 26, pp. 1, 3, 20; Ref. 27, p. 1; Ref. 60, pp 1, 2, 3]. 
Surface Water Migration Pathway – Overland Flow

Likelihood of Release

Keddy Mill HRS Documentation Record 

MEN000106078 48 

 The highest concentrations of PCBs detected in sediment samples occurred slightly 

downstream of PPE No. 2 and decreased with distance from the PPEs [Ref. 38, pp. 21, 

26; Ref. 63, pp. 46, 48, 49, 50]. 

 Based on a review of EPA regulated facilities, no other sources of PCBs along the 

impacted downstream reach of the Presumpscot River have been identified [Ref. 62]. 

 Based on a review of aerial photography and municipal zoning, the primary land use 

along the banks of the Presumpscot River upstream of Keddy Mill and along downstream 

TDL is undeveloped or rural residential/agricultural [Ref. 48, p. 1; 67, p. 1]. Other 

regional land use includes: Gambo Dam and power station located 1.5 miles upstream of 

the Keddy Mill property (at the background sediment sample SED-01); lumber 

manufacturing located approximately 1,000 feet north of the Keddy Mill property; and a 

former mill located slightly downstream of sediment sample SED-16) [Ref. 67, p. 2]. 

Hazardous Substances Released

Aroclor-1248 

Aroclor-1254 

Surface Water Observed Release Factor Value: 550 
Surface Water Migration Pathway – Overland Flow 

Human Food Chain Threat – Waste Characteristics 

Keddy Mill HRS Documentation Record 

MEN000106078 49

4.1.3.2 HUMAN FOOD CHAIN THREAT WASTE CHARACTERISTICS 

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation 

The Toxicity, Persistence, and Bioaccumulation Factor Values are assigned to the hazardous 

substances associated with the sources and releases at Keddy Mill property based on the values 

presented in the Superfund Chemical Data Matrix (SCDM) [Ref. 2, pp. 20, 21]. 

The TDL for this watershed is comprised entirely of the Presumpscot River, which is a 

freshwater river [Ref. 39, pp. 1, 2]. Therefore the Toxicity, Persistence, and Bioaccumulation 

Factor Values for freshwater river watersheds are used [Ref. 2, p. 21]. Aroclor-1248, Aroclor1242, and Aroclor-1254 are not listed in the SCDM. Therefore, the factor value for non-specific 

PCBs as cited in SCDM is assigned in Table 21 below [Ref. 47, p. 1]. 

Table 21 - Toxicity, Persistence, Bioaccumulation Factor Values

Hazardous 

Substance

Source 

No.

Toxicity 

Factor 

Value

Persistence 

Factor 

Value

Bioaccumulation 

Factor Value

Toxicity/Persistence/

Bioaccumulation 

Factor Value

Reference

PCBs 1, 2 10,000 1.0 50,000 5.0×108

Ref. 1, 

Section 

4.1.3.2.1.4, 

p. 51618; 

Ref. 2, p. 

21

Notes: 

No. = Number 

PCBs = Polychlorinated Biphenyls

The highest combined toxicity, persistence, and bioaccumulation factor value is for PCBs is

5×108.

Toxicity/Persistence/Bioaccumulation Factor Value: 5.0 ×108 

[Ref. 1, Section 4.1.3.2.1.4, p. 51618] 

4.1.3.2.2 HAZARDOUS WASTE QUANTITY 

Table 22 - Hazardous Waste Quantity

Source No. and Source 

Type

Source Hazardous Waste Quantity 

Value (Section 2.4.2.1.5)

Is source hazardous constituent quantity 

data complete? (yes/no)

1 – Contaminated Soil 0.448 No

2 - Contaminated Soil 1.87 No

Source Hazardous Waste Quantity Value Sum: 2.318 
Surface Water Migration Pathway – Overland Flow 

Human Food Chain Threat – Waste Characteristics 

Keddy Mill HRS Documentation Record 

MEN000106078 50

Based upon HRS Table 2-6, the sum of the individual Source Hazardous Waste Quantity Values 

(2.318) is between 1 and 100; however, because the hazardous constituent quantity is not 

adequately determined and because targets in this pathway are subject to Level II actual 

contamination, a hazardous waste quantity factor value of 100 is assigned [Ref. 1, Section 

2.4.2.2, p. 51592; Section 4.1.4.3 of this HRS Documentation Record]. 

Hazardous Waste Quantity: 100 

[Ref. 1, Section 2.4.2.2, pp. 51591, 51592] 

4.1.3.2.3 Waste Characteristics Factor Category Value 

The Toxicity/Persistence Factor Value (10,000) is multiplied by the Hazardous Waste Quantity 

Factor Value for the watershed (100) in order to determine the Waste Characteristics Product, 

subject to a maximum value of 1 × 108(Ref. 1, Section 4.1.3.2.3, p. 51620). 

Toxicity/Persistence Factor Value × Hazardous Waste Quantity Factor Value: 1.0×106

The product of the Toxicity/Persistence Factor Value and the Hazardous Waste Quantity Factor 

Value for the watershed is multiplied by the Bioaccumulation Potential Factor Value for PCBs 

(50,000), subject to a maximum value of 1 × 1012 (Ref. 1, Section 4.1.3.2.3, p. 51620). 

Toxicity/Persistence Factor Value (10,000) × 

Hazardous Waste Quantity factor value (100) × 

Bioaccumulation Factor Value (50,000) = 5.0×1010

Based upon HRS Table 2-7, a Waste Characteristics Factor Value of 5.0×1010 is assigned a 

Waste Characteristics Factor Category Value of 320 [Ref. 1, Section 2.4.3.1, Table 2-7, p. 

51592].

Waste Characteristics Factor Category Value: 320

[Ref. 1, Section 2.4.3.1, Table 2-7, p. 51592] 
Surface Water Migration Pathway – Overland Flow 

Human Food Chain Threat – Targets 

Keddy Mill HRS Documentation Record 

MEN000106078 51

4.1.3.3 Human Food Chain Threat Targets 

Actual Human Food Chain Contamination

The Presumpscot River supports both cold water and warm water fisheries that are managed by 

the Maine Department of Inland Fisheries and Wildlife (MDIFW) [Ref. 37, p. 7; Ref. 49; Ref. 

50]. The MDIFW stocks the river with brook trout, brown trout, and landlocked salmon in 

locations upstream (Eel Weir, Dundee Falls) and downstream (Mallison Falls) of the Keddy Mill 

property; however, the stretch of river between Little Falls and Mallison Falls is not stocked by 

MDIFW [Ref. 49; Ref. 50; Ref. 51, pp. 6, 7]. It should be noted that a fishing access path is 

located along the western river bank at the Mallison Street Bridge (slightly upstream of Mallison 

Falls). During the April 26, 2012 SI reconnaissance, evidence of fishing (empty bait container 

and coiled fishing line) was observed at the river’s edge at the base of the fishing access path

[Ref. 26, p. 4]. Fishing for human consumption was not documented between the PPEs and the 

most downstream sample (SED-16); however it is documented downstream within the 15-mile 

TDL and therefore is scored under potential contamination (refer to Section 4.1.3.3.2.3 of this 

HRS Documentation Record). 

Actual Food Chain Contamination Value: 0

4.1.3.3.1 Food Chain Individual 

The Presumpscot River supports both cold water and warm water fisheries that are managed by 

the Maine Department of Inland Fisheries and Wildlife (MDIFW) [Ref. 37, p. 7; Ref. 49; Ref. 

50]. The MDIFW stocks the river with brook trout, brown trout, and landlocked salmon in 

locations upstream (Eel Weir 11.5 miles upstream, Dundee Falls 6 miles upstream, Gambo Falls 

2 miles upstream) and downstream (Mallison Falls 0.8 miles downstream) of the Keddy Mill 

property; however, the stretch of river between Little Falls and Mallison Falls is not stocked by 

MDIFW [Ref. 49, pp. 1, 2, 4; Ref. 50; Ref. 51, pp. 6, 7]. It should be noted that a fishing access 

path is located along the western river bank at the Mallison Street Bridge (slightly upstream of 

Mallison Falls). During the April 26, 2012 SI reconnaissance, evidence of fishing (empty bait 

container and coiled fishing line) was observed at the river’s edge at the base of the fishing 

access path [Ref. 26, p. 4]. 

During a wetland delineation effort conducted as part of the EPA SI on July 24, 2012, EPA 

interviewed a fisherman encountered slightly below the Mallison Falls Dam and outfall structure 

and powerhouse, downstream of the observed release and within the 15-mile TDL. The 

fisherman stated that he had often caught brown trout and occasionally salmon, and regularly 

kept fish for consumption. He also stated that many people fish the area and consume their catch 

[Ref. 52, p. 1]. 

An observed release of hazardous substances (refer to Section 4.1.2.1.1 of this HRS 

Documentation Record) having Bioaccumulation Factor Values of 500 or greater to a perennial 

surface water with a fishery downstream is documented. 
Surface Water Migration Pathway – Overland Flow 

Human Food Chain Threat – Targets 

Keddy Mill HRS Documentation Record 

MEN000106078 52

Although Actual Food Chain contamination cannot be documented, a documented Human Food 

Chain fishery is present within the TDL [Ref. 37, p. 7; Ref. 49; Ref. 50; Ref. 51, pp. 6, 7; Ref. 

52, p. 1]. Therefore, a Food Chain Individual value of 20 is assigned [Ref. 1, p. 83]. 

Food Chain Individual Value: 20

[Ref. 1, p. Section 4.1.3.3.1, p. 51620] 

4.1.3.3.2 Population 

No Level I or Level II concentrations have been documented. 

Level I Human Food Chain Population Value: 0

[Ref. 1, Sections 4.1.3.3.2.1, pp. 51620] 

Level II Human Food Chain Population Value: 0

[Ref. 1, Sections 4.3.3.2.2, pp. 51620] 

4.1.3.3.2.3 Potential Human Food Chain Contamination 

The Presumpscot River is designated as a fishery; however, fishery production values for the 

fishery are not known [Ref. 37, p. 7; Ref. 49, p. 1; Ref. 50, p. 1; Ref. 51, pp. 6, 7; Ref. 52, p. 1]. 

Therefore, a value of greater than 0 is used to obtain an assigned Human Food Chain Population 

value of 0.03 from HRS Table 4-18 [Ref. 1, Table 4-18, p. 51621] because fishing for human 

consumption is known to occur within the TDL [Ref. 52]. 

USGS gauging station No. 01064118 is located within approximately 7 miles downstream of 

PPE No. 3, in Westbrook, Maine [Ref. 39, p. 2]. The discharge at this station is 925 cubic feet 

per second (cfs), and estimated to be 981 cfs at the terminus of the TDL [Ref. 39, p. 1]. 

According to HRS Table 4-13, a dilution weight of 0.01 (Moderate to Large Stream) is assigned 

to the watershed [Ref. 1, Table 4-13, p. 51613].

The Potential Human Food Chain Contamination Factor Value is calculated by multiplying the 

Human Food Chain Population value by the dilution weight for a Moderate to Large Stream, and 

dividing by 10 [Ref. 1, Section 4.1.3.3.2.3, p. 51621].

(0.03 × 0.01) ÷ 10 = 0.00003 

Potential Human Food Chain Contamination Factor Value = 0.00003 

[Ref. 1, Section 4.1.3.3.2.3, p. 51621] 
Surface Water Migration Pathway – Overland Flow 

Environmental Threat – Waste Characteristics 

Keddy Mill HRS Documentation Record 

MEN000106078 53

4.1.4.2 ENVIRONMENTAL THREAT WASTE CHARACTERISTICS 

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation 

The Ecosystem Toxicity, Persistence, and Bioaccumulation Factor Values are assigned to the 

hazardous substances associated with the sources and releases at the Keddy Mill property based 

on the values presented in the SCDM [Ref. 2, pp. 20, 21]. 

The TDL for this watershed is comprised entirely of the Presumpscot River, which is a 

freshwater river [Ref. 39, pp. 1, 2]. Therefore the Ecosystem Toxicity, Persistence, and 

Bioaccumulation Factor Values for freshwater river watersheds are used [Ref. 2, p. 21]. 

Ecosystem Toxicity, Persistence, and Bioaccumulation Factor Values are not currently available 

for Aroclor-1242, Aroclor-1248, or Aroclor-1254. Therefore the factor value for non-specific 

PCBs as cited in SCDM is assigned in Table 23 below [Ref. 47, p. 1]. 

Table 23 - Ecosystem Toxicity, Persistence, Bioaccumulation Factor Values

Hazardous 

Substance

Source 

No.

Ecosystem 

Toxicity 

Factor 

Value

Persistence 

Factor 

Value

Ecosystem 

Bioaccumulation 

Factor Value

Ecosystem 

Toxicity/Persistence/

Bioaccumulation 

Factor Value

Reference

PCBs 1, 2 10,000 1.0 50,000 5.0×108

Ref. 1, 

Section 

4.1.4.2.1.4, 

p. 51622; 

Ref. 2, p. 

21

Notes: 

No. = Number 

PCBs = Polychlorinated Biphenyls

The highest combined Ecosystem Toxicity, Persistence, and Bioaccumulation factor value is for 

PCBs: 5×108. 

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 5.0 ×108

[Ref. 1, Section 4.1.4.2.1, p. 51621] 

4.1.4.2.2 HAZARDOUS WASTE QUANTITY 

Table 24 - Hazardous Waste Quantity

Source No. and Source 

Type

Source Hazardous Waste Quantity 

Value (Section 2.4.2.1.5)

Is source hazardous constituent quantity 

data complete? (yes/no)

1 – Contaminated Soil 0.448 No

2 - Contaminated Soil 1.87 No

Source Hazardous Waste Quantity Value Sum: 2.318 
Surface Water Migration Pathway – Overland Flow 

Environmental Threat – Waste Characteristics 

Keddy Mill HRS Documentation Record 

MEN000106078 54

Based upon HRS Table 2-6, the sum of the individual Source Hazardous Waste Quantity Values 

(2.318) is between 1 and 100; however, because the hazardous constituent quantity is not 

adequately determined and because targets in this pathway are subject to Level II actual 

contamination, a hazardous waste quantity factor value of 100 is assigned [Ref. 1, Section 

2.4.2.2, p. 51592; Section 4.1.4.3 of this HRS Documentation Record]. 

Hazardous Waste Quantity: 100 

[Ref. 1, Section 2.4.2.2, pp. 51591, 51592] 

4.1.4.2.3 WASTE CHARACTERISTICS FACTOR CATEGORY VALUE 

The Ecosystem Toxicity/Persistence Factor Value (10,000) is multiplied by the Hazardous Waste 

Quantity Factor Value for the watershed (100) in order to determine the Waste Characteristics 

Product, subject to a maximum value of 1 × 108(Ref. 1 Section 4.1.4.2.3, p. 51624). 

Toxicity/Persistence Factor Value × Hazardous Waste Quantity Factor Value: 1.0×106

The product of the Ecosystem Toxicity/Persistence Factor Value and the Hazardous Waste 

Quantity Factor Value for the watershed is multiplied by the Ecosystem Bioaccumulation 

Potential Factor Value for PCBs (50,000), subject to a maximum value of 1 × 1012 (Ref. 1, 

Section 4.1.4.2.3, p. 51624). 

Ecosystem Toxicity/Persistence Factor Value (10,000) × 

Hazardous Waste Quantity factor value (100) × 

Ecosystem Bioaccumulation Factor Value (50,000) = 5.0×1010

Based upon HRS Table 2-7, a Waste Characteristics Factor Value of 5.0×1010 is assigned a 

Waste Characteristics Factor Category Value of 320 [Ref. 1, Section 2.4.3.1, Table 2-7, p. 

51592].

Waste Characteristics Factor Category Value: 320

[Ref. 1, Section 2.4.3.1, Table 2-7, p. 51592] 
Surface Water Migration Pathway – Overland Flow 

Environmental Threat – Targets 

Keddy Mill HRS Documentation Record 

MEN000106078 55

4.1.4.3 ENVIRONMENTAL THREAT – TARGETS 

The Keddy Mill property is located adjacent to the Presumpscot River and the Little Falls Dam. 

The property is within the Presumpscot River drainage basin [Ref. 12, pp. 10, 18; Ref. 36, pp. 

85, 86]. 

The Federal Water Pollution Control Act (also referred to as the Clean Water Act [CWA]) 

Section 305(a) compelled the States to provide an inventory of navigable waters for which the 

quality is sufficient to provide for the protection and propagation of a balanced population of 

shellfish, fish, and wildlife; and allow for recreation in and on the water; or can reasonably be 

expected to attain such a level within a specified timeframe [Ref. 56, p. 116]. 

The State of Maine has classified the Presumpscot River between Dundee Pond (upstream of the 

Keddy Mill property) and Sacarappa Falls as Class B surface water [Ref. 54, p. 11]. Maine Class 

B surface waters shall be of such quality that they are suitable for the designated uses of drinking 

water supply after treatment, fishing, agriculture, recreation in and on the water, industrial 

process and cooling water supply, hydroelectric power generation except as prohibited under 

Title 12 Section 403, navigation, and as habitat for fish and other aquatic life. The habitat must 

be characterized as unimpaired [Ref. 55, pp. 2]. Discharges to Class B waters may not cause 

adverse impact to aquatic life in that the receiving waters must be of sufficient quality to support 

all aquatic species indigenous to the receiving water without detrimental changes to the resident 

biological community [Ref. 55, p. 3]. The 2010 Maine Integrated Water Quality Monitoring and 

Assessment Report (commonly referred to as Section 305(b)) states that the Presumpscot River 

(Maine Assessment Unit ID No. ME0106000103_608R01) between Dundee Dam and 

Sacarrappa Falls Dam is impaired by the presence of impoundments (Category 4-C). [Ref. 68, p. 

267]. Additionally, EPA has indicated that the designated use of this portion of the river by fish 

and other aquatic life has been impaired [Ref. 69, p. 1]. Therefore, based upon these 

classifications, the Presumpscot River is a State-designated area for protection or maintenance of 

aquatic life as prescribed in Section 305(a) of the Clean Water Act [Ref. 54, p. 11; Ref. 55, pp. 2, 

3; Ref. 56, p. 116]. 

On July 24, 2012, a Senior EPA Wetland Scientist performed a wetland frontage delineation 

within the Presumpscot River. This delineation identified approximately 0.78 miles of riverine 

lower perennial emergent nonpersistent wetland frontage within the Presumpscot River between 

Little Falls and Mallison Falls [Ref. 57, pp. 1, 3, 13, 14]. 

As indicated in Section 4.1.2.1.1 of this HRS Documentation Record, an observed release of 

PCBs to the Presumpscot River has been documented, which has impacted a State-designated 

area for protection or maintenance of aquatic life as prescribed in Section 305(a) of the Clean 

Water Act [Ref. 1, Table 4-23, p. 51624; Ref. 56, p. 116]. Additionally, this release has 

impacted wetlands located along the Presumpscot River between Little Falls and Mallison Falls. 

Level I Concentrations

No Level I concentrations have been documented. 
Surface Water Migration Pathway – Overland Flow

Environmental Threat – Targets

Keddy Mill HRS Documentation Record 

MEN000106078 56

Level II Concentrations

Actual contamination has been documented in riverine lower perennial emergent nonpersistent 

wetlands contiguous with the Presumpscot River and in a State-designated area for protection or 

maintenance of aquatic life as prescribed in Section 305(a) of the CWA, as documented in 

Section 4.1.2.1.1 of this HRS documentation record [Ref. 54, p. 11; Ref. 55, p. 2; Ref. 56, p. 116; 

Ref. 57, pp. 1-3, 14].

Most Distant Level II Sample

Sample ID: SED-16 

Hazardous Substance: Aroclor-1254 

Distance from PPE No. 1: 0.603 miles 

References: 45 

4.1.4.3.1 Sensitive Environments 

4.1.4.3.1.1 Level I Concentrations 

Sensitive Environments

No Level I Sensitive Environments were scored. 

Wetlands

No Level I wetlands were scored. 

4.1.4.3.1.2 Level II Concentrations 

Sensitive Environments

As summarized in Table 20 in Section 4.1.2.1.1 of this HRS Documentation Record, 

Presumpscot River sediment samples contained concentrations of PCBs significantly above 

background levels, documenting an Observed Release. Additionally, these results indicate that 

Level II Actual Contamination has been documented within a State-designated area for 

protection or maintenance of aquatic life as prescribed in Section 305(a) of the CWA. Table 25 

below provides a summary of the sensitive environment targets. 
Surface Water Migration Pathway – Overland Flow 

Environmental Threat – Targets 

Keddy Mill HRS Documentation Record 

MEN000106078 57

Table 25 – Level II Sensitive Environment Targets

Sensitive Environment Distance from PPE to 

Sensitive Environment

Sensitive Environment 

Value (Ref. 1, Table 4-23)

References

Presumpscot River

(state designated area for the 

protection or maintenance of 

aquatic life under the Clean 

Water Act)

0 5

Ref. 54 p. 11; Ref. 

55, p. 3; Ref. 56, p. 

116

Notes: 

PPE: Probable Point of Entry 

Sum of Level II Sensitive Environments Value: 5 

Wetlands 

On July 24, 2012, an EPA Senior Wetland Scientist delineated wetlands along and contiguous to 

the Presumpscot River [Ref. 26, pp. 4, 5; Ref. 57, p. 1]. The wetland areas delineated are 

riverine lower perennial emergent nonpersistent [Ref. 57, p. 3]. The sediment samples evaluated 

at Level II concentrations were collected adjacent to these wetland areas (see Figure 6 of this 

HRS documentation record). 

During wetland delineation activities, a series of emergent wetland fringes of varying lengths and 

thicknesses were identified. The principle emergent wetland species encountered was Arrow 

Arum (Peltandra virginica); however, lesser amounts of Pickerelweed (Pontederia cordata L.) 

were also noted. The emergent plants are not likely persistent, and therefore the United States 

Fish and Wildlife Service (USFWS) National Wildlife Inventory (NWI) classification of this 

wetland is R2EM2 – Riverine Lower Perennial Emergent Nonpersistent [Ref. 57, p. 3]. 

The delineated wetland frontage between Little Falls and Mallison Falls totaled 0.78 miles [Ref. 

57, pp. 14, 16]. The most-distant sediment sample documenting an Observed Release is SED16, located downstream of the entire length of delineated wetlands; therefore, 0.78 miles of 

wetland frontage located along the Presumpscot River is subject to Level II Actual 

Contamination, [Ref. 45; Ref. 57, p. 14]. Table 26 provides a summary of wetland frontage 

targets. 

Table 26 – Level II Wetland Frontage

Wetland Water Body Wetland Frontage in 

Miles (Ref. 1, Table 4-24) References

Riverine lower perennial 

emergent nonpersistent Presumpscot River 0.78 Ref. 45, pp. 12; Ref. 57, pp, 14, 16

Sum of Level II wetland frontages: 0.78 miles 

Wetland Value: 25 

[Ref. 1, Table 4-24, p. 51625] 

For sensitive environments and wetlands subject to Level II concentrations, the values assigned 

are summed and multiplied by 1 (5 + 25 × 1 = 30) [Ref. 1, Section 4.1.4.3.1.2, p. 51625]. 

Level II Concentrations Factor Value: 30 
Surface Water Migration Pathway – Overland Flow 

Environmental Threat – Targets 

Keddy Mill HRS Documentation Record 

MEN000106078 58

4.1.4.3.1.3 Potential Contamination 

Actual contamination is sufficient to qualify the Site for NPL listing. Therefore the Potential 

Contamination Factor was not scored. 

Potential Contamination Factor Value: Not Scored